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ICSI Seeks CCFS 2026 Extension Till September 30 Amid MCA-21 Filing Issues

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Summary: ICSI has requested the Ministry of Corporate Affairs (MCA) to grant a one-time extension of the Company Compliance Facilitation Scheme (CCFS) 2026 beyond August 31, 2026, preferably up to September 30, 2026. The representation was made by the Institute of Company Secretaries of India (ICSI) through letter G&CL: MCA: AUG:08 / 2026 dated August 28, 2026 addressed to Dr Pallavi Jain Govil, Hon’ble Secretary, Ministry of Corporate Affairs.

The representation follows ICSI’s earlier letter G&CL: MCA: AUG:01 / 2026 dated 20.08.2026, in which the Institute had also sought extension of CCFS 2026. The present representation states that companies and professionals are facing practical difficulties in completing pending statutory compliances because of the large number of filings involved and technical issues being experienced on the MCA-21 V3 portal.

ICSI points out that several companies and professionals require additional time to obtain necessary approvals and complete their filing processes. It identifies pending financial and tax-related matters as one reason for delay, noting that accounts and consequential statutory filings could not be completed in some cases because of pending Income-tax compliances, reconciliation of financial records and completion of related audit requirements.

The Institute also highlights the time required to regularise long-pending defaults. Companies with historical non-compliances may need to trace and compile earlier records, obtain supporting documents, complete audits, secure approvals and undertake professional certifications. According to ICSI, these difficulties are particularly significant for SMEs, inactive companies and entities having prolonged periods of non-compliance.

Another difficulty concerns pre-requisites for filing by defaulting companies. Where DINs are inactive or deactivated, additional time may be required for KYC compliance, renewal of Digital Signature Certificates (DSCs), DIN reactivation and consequential system updation. ICSI states that these dependencies are delaying the filing of pending forms under CCFS 2026.

The representation further notes the concentration of statutory work during August-September, when companies and professionals are required to attend to several Income-tax, tax audit, GST and other statutory compliances. ICSI states that the residual workload arising from the earlier MCA-21 outage has further contributed to delays in completing CCFS-related filings.

ICSI has also drawn attention to companies undergoing revival or restoration proceedings. Several companies seeking regularisation of past defaults are simultaneously pursuing restoration of their names under Section 252 of the Companies Act, 2013. The Institute states that completion of pending filings and other compliances is often necessary to support such proceedings and comply with directions of the Hon’ble National Company Law Tribunal (NCLT).

Against this background, ICSI has requested the Ministry to consider a one-time extension of CCFS 2026 beyond August 31, 2026, preferably until September 30, 2026. The Institute states that the additional period would provide genuine stakeholders with a meaningful opportunity to complete pending compliances and would contribute to enhanced corporate compliance and ease of doing business.

The representation also records that ICSI shall not be giving any further proposals with respect to extension of the Scheme and offers to furnish any additional information or clarification required by the Ministry. The request remains a representation to the Ministry; the supplied material does not state that any extension beyond August 31, 2026 has been granted.

The Institute of Company Secretaries Of India

G&CL: MCA: AUG:08 / 2026 | Dated: August 28, 2026

Dr Pallavi Jain Govil
Hon’ble Secretary
Ministry of Corporate Affairs
Government of India

Respected Madam,

Subject: Representation for extension of the Company Compliance Facilitation Scheme (CCFS) 2026

Greetings from the Institute of Company Secretaries of India!

This is in reference to ICSI letter G&CL: MCA: AUG:01 / 2026 dated 20.08.2026. (Copy of letter enclosed) requesting for one time extension of Company Compliance Facilitation Scheme, 2026 (CCFS).

We wish to draw your kind attention towards the practical difficulties being faced by companies and professionals in completing pending statutory compliances under the CCFS 2026 due to large number of filings involved, coupled with technical issues being experienced on the MCA-21 V3 portal.

In several cases, companies and professionals require additional time to obtain necessary approvals and complete the filing process.

In view of the above, we respectfully request you to kindly consider to minimum extension of the Company Compliance Facilitation Scheme (CCFS) 2026 preferably upto September 30, 2026.

ICSI Submission

The request for a one-time extension is supported by the following considerations:

1. Pending Financial and Tax-related Matters: In a number of cases, accounts and consequential statutory filings could not be completed within the stipulated timeframe due to pending Income-tax compliances, reconciliation of financial records and completion of related audit requirements.

2. Time Required for Regularisation of Past Defaults: Companies having long-pending defaults are required to trace and compile records relating to earlier years, obtain supporting documents, complete audits, secure necessary approvals and undertake professional certifications. This process is particularly challenging for SMEs, inactive companies and entities having prolonged periods of non-compliance.

3. Pre-requisites for Filing by Defaulting Companies: In cases where DINs are inactive or deactivated, additional time is required for completion of KYC requirements, renewal of DSCs, DIN reactivation and consequential system updation. These dependencies are delaying the filing of pending forms under the Scheme.

4. Concentration of Statutory Work during August-September: The period coincides with several important Income-tax, tax audit, GST and other statutory compliances, resulting in substantial pressure on companies as well as professionals. The residual workload arising from the earlier MCA-21 outage has further contributed to the delay in completing CCFS-related filings.

5. Companies under Revival/Restoration Process: Several companies seeking regularisation of past defaults are also pursuing restoration of their names under Section 252 of the Companies Act, 2013. Completion of pending filings and other compliances is often necessary for supporting such proceedings and complying with the directions of the Hon’ble NCLT. An extension would provide these companies a meaningful opportunity to complete the requisite compliances and facilitate their revival and restoration.

In view of the above, and keeping in view the underlying objective of CCFS 2026 to provide an one-time opportunity for regularisation of historical defaults, ICSI respectfully requests the Ministry to consider a one-time extension of the Scheme beyond 31 August 2026, preferably up to 30 September 2026. The extension would enable genuine stakeholders to complete the pending compliances and contribute to the objectives of enhanced corporate compliance and ease of doing business.

ICSI shall be grateful if the Ministry may kindly consider the above request in the larger interest of stakeholders and corporate compliance. We shall not be giving any further proposals with respect to extension for this scheme.

We will be pleased to furnish any additional information/clarification required in this matter.

Thanking you,

Yours faithfully,

(CS Rawan G Chandak)
President
The Institute of Company Secretaries of India

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