CCFS-2026 closes 31 August: file overdue ROC returns at 10% fee
The Companies Compliance Facilitation Scheme 2026 closes 31 August 2026. Companies can file overdue annual returns, financial statements, and other ROC forms at just 10% of the normal late fee. After that date, standard ₹100/day penalties and strike-off action resume.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Companies (Filing of Documents and Furnishing of Information) Rules, 2015 — Section 403 (additional fee) and Section 454 (adjudication); General Circular 01/2026 dated 24 February 2026 and General Circular 03/2026 dated 8 July 2026 (extension notification). Source: mca-rbi)).gov.in. Last reviewed by CA Harun Raaj: August 2026.
If your company has missed filing its annual return (MGT-7), financial statements (AOC-4), or other ROC forms in previous years, the window to regularise those defaults at drastically reduced late fees closes on 31 August 2026.
The Companies Compliance Facilitation Scheme 2026 (CCFS-2026), introduced by MCA via General Circular 01/2026 dated 24 February 2026, gives companies a one-time opportunity to file pending returns at just 10% of the normal additional (late) fee. Originally closing on 15 July 2026, the deadline was extended to 31 August 2026 via General Circular 03/2026 dated 8 July 2026. From 1 September 2026, the standard ₹100/day additional fee resumes — and the ROC can initiate adjudication and strike-off action.
What CCFS-2026 Covers
Under CCFS-2026, you pay only 10% of the additional (late) fee amount. The scheme does not waive the base penalty entirely, but the reduction is substantial for companies with multiple years of arrears. For example, one year of overdue AOC-4 accrues approximately ₹36,500 in late fees; under the scheme, you pay approximately ₹3,650.
CCFS-2026 does NOT cover: LLP forms (Form-8, Form-11), charge-related forms (CHG-1, CHG-9), or criminal proceedings already launched. Additionally, if a Section 248 strike-off notice has already been issued, you cannot use CCFS-2026; instead, you must respond to the strike-off notice or apply for restoration separately.
Key point: File all overdue AOC-4, MGT-7, ADT-1, MSME-1, BEN-2, and DPT-3 forms by 31 August 2026 at 10% of standard late fees; after that date, normal ₹100/day penalties and strike-off proceedings resume.
Who Should Act Immediately
Companies with missed annual filings (AOC-4 and MGT-7)
AOC-4 and MGT-7 are the two highest-impact defaults. Non-filing for two consecutive years exposes your company to strike-off under Section 248. Beyond that, directors face disqualification under Section 164(2)(a) for three consecutive years of non-compliance. Use CCFS-2026 to clear arrears before this escalation occurs.
Auditor appointment not filed (ADT-1)
ADT-1 must be filed within 15 days of the AGM at which the auditor is appointed. Non-filing attracts a ₹25,000 penalty. If your company appointed an auditor in a previous financial year but failed to file ADT-1, CCFS-2026 is your opportunity to regularise without the full penalty.
MSME supplier payment returns (MSME-1)
MSME-1 is a half-yearly return on payments overdue to Micro and Small Enterprises beyond 45 days. Missed filings from prior half-years can be cleared under CCFS-2026 at the reduced rate.
Beneficial ownership disclosure (BEN-2)
Any company with significant beneficial owners must file BEN-2. Overdue BEN-2 filings attract ₹10,000 + ₹1,000/day in late fees. The 10% rate under CCFS-2026 applies here as well.
Illustrative Example
ABC Private Limited, a Delhi-based company incorporated in November 2022, never filed its AOC-4 or MGT-7 for FY 2023-24 and FY 2024-25.
Normal late fee accrued (as at 31 August 2026):
- AOC-4 FY 2023-24: ~660 days overdue → ₹66,000 additional fee
- MGT-7 FY 2023-24: ~600 days overdue → ₹60,000 additional fee
- AOC-4 + MGT-7 FY 2024-25: approximately ₹1,00,000+
- Total normal penalty: approximately ₹2,26,000
Under CCFS-2026 (10%): approximately ₹22,600 total.
Additionally, by filing before 31 August 2026, the company avoids strike-off proceedings under Section 248 and director disqualification under Section 164(2)(a).
How to File Under CCFS-2026
- Log in to the MCA21 V3 portal at mca.gov.in using the company's registered email and Director DSC
- Prepare all overdue forms — AOC-4 requires auditor-signed financial statements; MGT-7 requires director, shareholder, and meeting details
- Navigate to the relevant e-form under your company's CIN page
- The portal automatically applies the 10% CCFS-2026 rate for filings submitted before 31 August 2026
- Attach all required documents — audited financial statements (for AOC-4), board resolutions, meeting minutes, and DSC
- Submit and pay — most private company AOC-4 filings are auto-approved after payment
Critical reminder: Your Director's DSC must be active and registered on MCA21 V3. If your DSC is expired, renew it before filing.
What Happens After 31 August 2026
From 1 September 2026:
- Standard ₹100/day additional fees resume
- ROC can initiate adjudication under Section 454 for underlying penalties
- ROC can issue strike-off notices under Section 248 for two consecutive years of non-filing
- Directors of companies with three consecutive years of non-filing face disqualification under Section 164(2)(a) for 5 years
Companies that file under CCFS-2026 signal compliance and typically avoid these escalations.
See Also
Frequently Asked Questions
What is CCFS-2026 and who does it apply to?+
CCFS-2026 is the Companies Compliance Facilitation Scheme 2026, introduced by MCA via General Circular 01/2026 dated 24 February 2026. It applies to any registered private limited company that has overdue ROC filings (AOC-4, MGT-7, ADT-1, MSME-1, BEN-2, or DPT-3) from previous financial years. The scheme allows such companies to file these forms and pay only 10% of the normal additional (late) fee before 31 August 2026.
How much can I save using CCFS-2026 for overdue AOC-4 and MGT-7?+
Savings depend on how long the filings have been overdue. One year of overdue AOC-4 accrues approximately ₹36,500 in late fees; under CCFS-2026, you pay approximately ₹3,650 — a saving of about 90%. For two or three years of arrears, the savings compound significantly. For example, a company with two years of AOC-4 and MGT-7 arrears may save over ₹2 lakhs in late fees by using the scheme.
Do I need to file all overdue forms together, or can I file them separately?+
You can file overdue forms separately or together. Each form has its own filing deadline on the MCA21 portal, and the 10% CCFS-2026 rate applies to all eligible filings submitted before 31 August 2026. However, for maximum compliance benefit, file all arrears together — especially AOC-4 and MGT-7, which are the highest-risk defaults.
Does CCFS-2026 prevent ROC adjudication or strike-off proceedings?+
Filing under CCFS-2026 does not eliminate the underlying penalty structure, but it reduces the late fee and signals good faith compliance to the ROC. Adjudication under Section 454 remains technically open, but companies that file promptly under the scheme are unlikely to face initiation. However, if a Section 248 strike-off notice has already been issued, you cannot use CCFS-2026; you must respond to the notice separately or apply for restoration under Section 252.
My company's financial statements for FY 2024-25 are not yet audited. Can I still file AOC-4 for earlier years under CCFS-2026?+
Yes. File AOC-4 for all financial years for which you have audited financial statements available before 31 August 2026. Once your FY 2024-25 audit is complete, you can file that year's AOC-4 separately. Filing for earlier years does not prevent you from filing the most recent year later, as long as it is before the scheme deadline.
What happens if I miss the 31 August 2026 deadline?+
From 1 September 2026, the normal additional fee structure resumes — ₹100/day for AOC-4, ₹500/day for MGT-7, and fixed penalties for ADT-1, MSME-1, BEN-2, and DPT-3. Additionally, the ROC can initiate strike-off proceedings under Section 248 for companies with two consecutive years of non-filing and adjudication under Section 454 for the full underlying penalty.
Does my Director's DSC need to be valid to file under CCFS-2026?+
Yes. Your Director's DSC must be active and registered on MCA21 V3 to file any form. If your DSC has expired, renew it before attempting to file overdue forms. The MCA21 portal will not accept filings without a valid, registered Director DSC.
Can I file CCFS-2026 forms if my company is already under a show-cause notice or strike-off notice?+
If a Section 248 strike-off notice has been issued, you cannot file under CCFS-2026; instead, you must respond to the notice or apply for restoration under Section 252 with legal and professional guidance. If a show-cause notice for adjudication has been issued but the company is not yet struck off, consult your CA or Company Secretary immediately to determine the best course of action.
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