The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) introduced by the Ministry of Corporate Affairs provides a one-time opportunity for companies to regularize pending statutory filings or exit the corporate registry at significantly reduced costs. The scheme will operate from April 15, 2026, to July 15, 2026, allowing companies to file overdue annual compliance forms such as MGT-7/MGT-7A (Annual Returns) and AOC-4 series (Financial Statements) by paying normal filing fees plus only 10% of the additional fees, offering major financial relief from accumulated penalties. The scheme also enables companies to apply for Dormant Status through MSC-1 at 50% of the normal fee or strike off through STK-2 at 25% of the filing fee. Immunity from penal action is granted for delayed filings under Sections 92 and 137, provided filings are completed within the scheme period and before enforcement proceedings begin. However, the scheme does not condone other statutory defaults such as failure to hold AGM, which must be addressed separately under the Companies Act, 2013.
A. Key Details of Scheme:
1. Scheme Duration: April 15, 2026, to July 15, 2026.
2. Eligible Annual Filing Related Forms:
| MGT-7 & MGT-7A | Annual Returns |
| AOC-4, AOC-4 CFS, AOC-4 (XBRL) | Financial Statements and Consolidated Financial Statements |
| AOC-4 NBFC (Ind AS) & AOC-4 CFS NBFC (Ind AS) | Financial Statements for NBFCs. |
| ADT-1 | Appointment of Auditors |
| FC-3 & FC-4 | Forms related to Foreign Companies |
| Form 20B & Form 21A | Annual Returns |
| Form 23AC & Form 23ACA | Balance Sheet and Profit & Loss Account |
| Form 23AC-XBRL & Form 23ACA-XBRL | XBRL filings for financial statements |
| Form 66 | Compliance Certificate |
| Form 23B | Information by Auditor to Registrar |
3. Specialized Forms for Status Change:
The scheme also facilitates applications for companies wishing to become inactive or exit the registry:
Web-form MSC-1: Application for obtaining ‘Dormant Company’ status.
Web-form STK-2: Application for striking off the company name from the register.
B. Benefits:
1. Reduced Fees Structure
| Option | Forms/Process | Fee Relief |
| Annual Filings | Annual Forms | Normal Fees
Plus 10% of additional fees |
| Dormant Status | MSC-1 (Sec 455) | 50% of normal fee |
| Strike Off | STK-2 | 25% of filing fee i.e. Rs. 2,500 instead of Rs.10,000 |
2. Immunity
> For Annual Returns and Financial Statements (Sections 92 & 137)
No Penalty will be levied if the filings are made:
- Before issuance of notice by the adjudicating office; OR
Within 30 days of issuance of such notice
> For Other Relevant e-Forms
Immunity from prospective penal action shall be granted if:
- Forms are filed under the Scheme; AND
- No prosecution has been filed or adjudication proceedings (through show cause notice) have been initiated for that specific default prior to filing.
3. Applicability of Scheme:
All companies are covered under this scheme except following:
1. Companies against which a final notice for striking off has already been issued under Section 248 of the Companies Act, 2013 (or Section 560 of the Companies Act, 1956).
2. Companies that have already applied for voluntary striking off.
3. Companies that filed an application for Dormant Status under Section 455 before April 15, 2026
4. Companies classified as “Vanishing Companies
4. Action of Registrar after the Scheme Expires:
i. Mandatory Enforcement Action: The Registrars of Companies (ROC) are specifically directed to take “necessary action under the Act” against any company that did not avail itself of the scheme and remains in default of filing its required documents
ii. Loss of Reduced Fee Benefits: The significant financial relief—where companies only pay 10% of the additional fees—will no longer be available. Defaulting companies will likely be subject to the standard additional fee of 100/- per day for delays in filing annual returns and financial statements, which accrues without any upper limit
iii. Strict Prosecution and Adjudication: Because the scheme is designed as a “one-time opportunity” to improve compliance levels, the Ministry intends for the corporate registry to reflect accurate information after July 15. Those who miss this window will be subject to the full weight of statutory penalties and legal proceedings as prescribed under the Companies Act, 2013
FAQ on CCFS-2026 Scheme
Q.1 Does the scheme cover non-conduct of AGM for the last 2 years?
Ans: The scheme focuses on condoning the delay in filing Annual Returns and Financial Statements. It only provides immunity from penal actions under Section 92 (Annual Return) and Section 137 (Financial Statements), but It does not cover default in holding AGM.
Q.2 If a company has not completed filings for the last 2 years, is the scheme applicable?
Ans: Yes, The scheme allows companies with pending annual filings to complete them by paying only 10% of the additional fees.
Q.3 Is this Scheme applicable for Annual Filing for FY 2024-25?
Ans: Since the scheme is active from April 15, 2026, to July 15, 2026, and applies to “relevant e-forms” due on any date, it would cover pending filings for the financial year 2024-25.
Q.4 How can a CA generate backdated UDIN for delayed filings?
Ans: UDIN generation is governed by ICAI guidelines and not covered under this scheme. UDIN must be generated on the current date and within ICAI-prescribed timelines.
Q.5 Are Forms INC-20A or DPT-3 covered?
Ans: No. Only the specified annual filing forms mentioned in the circular are covered.
Q.6 If STK-2 is filed under the scheme, must annual filings be completed?
Ans: If you file e-form STK-2 (for striking off) during the scheme, you only pay 25% of the filing fee and Company must be up-to-date with filings until it ceases operations or applies for strike-off.
Q.7 Benefit can be availed only if we file forms within the period of scheme…and if any other applications will be required to avail the benefits of scheme
Ans: Timeline: The benefits can only be availed for filings made between April 15, 2026, and July 15, 2026.
Application: No separate “immunity application” is required; the relief is granted upon the successful filing of the relevant e-forms and payment of the reduced fees (Normal fee + 10% of additional fee)
Q.8 If old audit reports were not signed earlier, how will UDIN be generated?
Ans: The auditor can generate UDIN on the current date and sign the financial statements accordingly.
Q.9 If additional fees were already paid earlier, can benefit be claimed
Ans: This scheme is specifically for completing “pending” filings if your filing is completed you are not eligible to avail benefit of scheme.
Q.10 Is the scheme applicable to companies already struck off?
Ans: No, the scheme is not applicable to companies that have already been struck off and that “Struck Off Company” would likely need to be restored to the register via the NCLT before it could file returns.
Q.11 Can any form be filed under this scheme?
Ans: No. Only specified “relevant web-forms” listed in the circular are eligible.
Q.12 Is UDIN required? What if AGM was not conducted?
Ans: UDIN must be generated as per ICAI norms. Delay in filing is condoned, but default in holding AGM remains and must be compounded separately.
Q.13 Is the scheme applicable to NBFCs?
Ans: Yes, NBFC companies are covered in the virtue of scheme.
Q.14 If UDIN was not generated before 30th September, what should be done?
Ans: The auditor may generate UDIN on the current date and sign the documents accordingly.
Q.15 Can correction in AGM date be made under this scheme?
Ans: No. The scheme is meant for pending filings, not for corrections.
Q.16 Can AOC-4 be re-filed to correct RPT disclosures of past years?
Ans: No. The scheme is intended only for pending annual compliances.
Q.17 How can Auditor generate backdated UDIN?
Ans: Auditor Can generate UDIN for current date and sign financial and Auditor Report and AGM will also get conducted in current dates.
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Author – CS Divesh Goyal, GOYAL DIVESH & ASSOCIATES Company Secretary in Practice from Delhi and can be contacted at csdiveshgoyal@gmail.com).
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