For many private companies, pending MCA annual filings gradually become a serious compliance burden. Since the introduction of fixed additional fees of Rs. 100 per day under Section 403 of the Companies Act, 2013, even a few years of non-filing can result in substantial additional fee exposure. In practice, many companies discover the scale of default only during bank due diligence, investor onboarding, GST scrutiny, or while applying for fresh funding.
To address this issue, the Ministry of Corporate Affairs (MCA) has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) vide General Circular No. 01/2026. The scheme is applicable from 15 April 2026 to 15 July 2026 and provides a one-time opportunity for companies to regularize pending filings, obtain dormant status, or opt for strike-off with significant fee relief.
The scheme is particularly beneficial for small and medium-sized private companies that were unable to complete annual compliances due to operational or financial difficulties.
Major Relief under CCFS-2026
The primary benefit of the scheme is the waiver of 90% of additional filing fees on specified forms. It is important to note that the concession applies only to additional fees and not to the normal statutory filing fees payable under the Companies (Registration Offices and Fees) Rules, 2014.
For example, if a company delayed filing Form MGT-7 for 400 days, the normal additional fee would be:
400 { days} *Rs. 100/{day} = Rs. 40,000Rs.
Under CCFS-2026, only 10% of the additional fee is payable. Accordingly, instead of paying Rs. 40,000 as additional fees, the company would pay only Rs. 4,000, resulting in a saving of Rs. 36,000 on a single form.
Where multiple forms such as AOC-4, MGT-7, MGT-7A, and ADT-1 are pending for several financial years, the cumulative relief can be substantial for MSMEs and closely held companies.
Key Compliance Options Available under the Scheme
Unlike earlier compliance schemes, CCFS-2026 provides flexibility depending on the operational status of the company.
1. Regularization of Pending Filings Companies that are active and intend to continue business operations can use the scheme to clear pending annual compliance filings. The scheme covers commonly delayed forms including:
- Form AOC-4 (and its variants like XBRL/CFS)
- Form MGT-7 / MGT-7A
- Form ADT-1
- Other eligible legacy forms under the 1956 Act (like Form 20B, 23AC, 66)
Crucially, filing under this window grants companies conditional immunity from prospective penal actions and adjudication proceedings regarding the delay, allowing management to completely reset their records cleanly.
2. Dormant Company Option under Section 455 Certain companies may not currently carry on business operations but may still hold assets, intellectual property, land, or future business plans. Such companies may opt for dormant status by filing Form MSC-1 under Section 455 of the Companies Act, 2013.
Under CCFS-2026, a 50% concession has been provided on the applicable filing fee for obtaining dormant status. This is a practical option for promoters who wish to retain the company structure while reducing ongoing compliance requirements.
3. Strike-Off of Defunct Companies For companies that have discontinued operations and have no assets or liabilities, the scheme also provides relief for voluntary strike-off through Form STK-2.
The filing fee for strike-off has been reduced significantly during the scheme period. Instead of the standard Rs. n10,000 filing fee, eligible companies can apply for strike-off by paying only 25% of the fee (Rs. 2,500) under the scheme. This provides an economical exit route for inactive private companies that no longer require corporate existence.
Why Companies Should Avoid Last-Minute Filing
Although the scheme remains open until 15 July 2026, companies should avoid delaying the filing process until the final weeks. The MCA V3 portal currently operates through multiple real-time validations, including:
- DSC association checks
- Director KYC verification
- PAN validation
- UDIN authentication
- Backend processing approvals
In many cases, old companies also face practical difficulties such as expired DSCs, non-updated DIN KYC, unavailable financial records, or a mismatch in director details.
Historically, heavy filing activity near compliance deadlines leads to portal congestion, payment failures, SRN processing delays, and unresolved technical tickets. If forms remain unfiled after the closure of the scheme period, normal additional fees may again become applicable from the original date of default.
Further, prolonged non-compliance may expose directors to disqualification risks under Section 164(2) of the Companies Act, 2013 and may also increase the possibility of regulatory action by the Registrar of Companies.
Conclusion
CCFS-2026 is a significant compliance relief measure introduced by the MCA for defaulting companies. The scheme not only reduces the financial burden of additional fees but also provides practical options for regularization, dormancy, and voluntary closure. Companies, accountants, and compliance professionals should conduct an immediate review of pending MCA filings and evaluate the most suitable course of action within the scheme period. Early preparation will also help avoid technical delays associated with MCA V3 filings during the last phase of the scheme.
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About the Author: Sheetal Chanchlani is a Practicing Company Secretary and founder of Sheetal Chanchlani & Associates, Chhattisgarh. The firm specializes in corporate compliance management, secretarial audits, ROC filings, and MCA regularization matters. The author can be reached at cssheetalchanchlani@gmail.com
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