A founder we spoke to last week ran the numbers on his two-year-old private limited company and went pale: three unfiled annual filings, a running additional fee of roughly ₹1.9 lakh, and a fast-approaching risk of director disqualification. Then he learned there was a government scheme that would let him clear all of it for about ₹19,000. He had ten days left to use it. If your company has any pending AOC-4 or MGT-7 filings, you are in exactly the same window — and it closes on 15 July 2026.
The scheme is the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), notified by the Ministry of Corporate Affairs through General Circular No. 01/2026 dated 24 February 2026. It is a one-time amnesty that waives 90% of the additional (late) fees on overdue annual filings and grants immunity from prosecution. Most founders either have not heard of it or assume "amnesty scheme" means something is wrong with their company. Neither assumption should cost you the waiver.
The pattern we see repeatedly is a founder who has one live, well-run company and one forgotten entity — a company floated for a project that never launched, a holding structure that was never used, a co-founder's earlier venture still on the register. Because nothing is "happening" in that entity, nobody files for it. The Act does not care whether the company traded; the filing obligation attaches to existence, not activity. CCFS-2026 exists precisely for these cases, and the fourteen days left before 15 July are the cheapest fourteen days you will get to fix them.
What the law actually requires
Two obligations sit at the centre of this. Under Section 137 of the Companies Act, 2013, every company must file its financial statements in Form AOC-4 (AOC-4, AOC-4 XBRL, AOC-4 CFS, and AOC-4 NBFC as applicable) within 30 days of the Annual General Meeting. Under Section 92, every company must file its annual return in Form MGT-7 (or MGT-7A for small companies and OPCs) within 60 days of the AGM. Auditor appointment is intimated in Form ADT-1 under Section 139.
When you miss these deadlines, Section 403 read with the Companies (Registration Offices and Fees) Rules, 2014 imposes an additional fee of ₹100 per day, per form, with no upper limit. This is the number that quietly compounds. A single AOC-4 that is 500 days late carries ₹50,000 in additional fee on its own — and it runs alongside the same clock on MGT-7.
CCFS-2026 does not change these sections. It temporarily reduces the fee consequence and suspends the prosecution consequence. Under the scheme, you file the pending forms and pay the normal filing fee plus only 10% of the accrued additional fee — a 90% reduction. On that ₹1.9 lakh example, the additional-fee component drops from roughly ₹1,90,000 to roughly ₹19,000. The scheme window runs from 15 April 2026 to 15 July 2026, and the forms covered include MGT-7, MGT-7A, the entire AOC-4 series, ADT-1, FC-3 and FC-4 for foreign companies, and corresponding forms under the 1956 Act.
Note one MCA21 v3 change while you are in the system: CSR-2 is now filed as part of AOC-4 on the V3 portal rather than as a standalone form, so companies with CSR obligations should confirm the CSR-2 web-form is completed within the AOC-4 flow before submission.
Two other reliefs sit inside the same circular for companies that do not want to keep trading. You can move a genuinely inactive company to dormant status under Section 455 by filing Form MSC-1 at half the normal filing fee, or you can wind it down entirely through strike-off under Section 248 by filing Form STK-2 at 25% of the normal fee. Both options are only available at these concessional rates until 15 July 2026; after that they revert to full fees and the strike-off route in particular becomes materially more expensive once the Registrar initiates it against you rather than the other way around.
Worked example: the real cost of waiting
Consider a private limited company incorporated in April 2022 with ₹10 lakh authorised capital that has never filed. By July 2026 it has three years of pending AOC-4 and three years of pending MGT-7 — six forms in default. The oldest forms are roughly 1,000 days late; the newest a few hundred. Run at ₹100 per day per form under Section 403, the accrued additional fee across the six forms lands in the region of ₹2.5 lakh to ₹3 lakh, entirely separate from the modest normal filing fees.
Under CCFS-2026, the additional-fee component is cut to 10%. That same company pays its normal fees plus roughly ₹25,000 to ₹30,000 in additional fee, and — critically — walks away with immunity from prosecution under Sections 92 and 137. Let 15 July pass, and not only does the discount vanish on the full accrued amount, but the company has now completed its third consecutive year of non-filing. That is the exact condition in Section 164(2) that disqualifies every director for five years. The difference between acting and waiting here is not ₹25,000 versus ₹2.7 lakh; it is a clean company versus a founder who cannot legally sit on any board until 2031.
Practical implications — what happens if you let 15 July pass
The waiver is not the only thing at stake. Ignoring pending filings past this window re-exposes you to the full machinery of the Act.
The additional fee resumes at full rate. From 16 July, every pending form is back to ₹100/day with no cap, and the meter has never stopped running — you simply lose the 90% discount on the entire accrued amount.
Monetary penalties under Sections 92 and 137 revive. For a defaulting annual return under Section 92(5), the company and every officer in default face a penalty of ₹10,000 plus ₹100 per day of continuing default, subject to a maximum of ₹2,00,000 for the company and ₹50,000 for each officer. Section 137(3) carries a parallel penalty for financial statements: ₹10,000 on the company plus ₹100/day (max ₹2,00,000), and ₹10,000 plus ₹100/day (max ₹50,000) on the managing director, CFO, or the directors responsible. These are adjudicated by the Registrar under Section 454 — you receive a notice, not a courtesy call. CCFS-2026 grants immunity from this prosecution for filings made under the scheme; miss the window and that immunity is gone.
Director disqualification under Section 164(2). This is the consequence founders underestimate most. If a company fails to file its financial statements or annual returns for three consecutive financial years, every director of that company is automatically disqualified for five years and cannot be reappointed to that company or appointed to any other company. The trigger is systemic — MCA21 v3 flags it against your DIN without any human decision. A single dormant, forgotten side-company can disqualify you across every board you sit on.
MCA21 v3 flags and strike-off. Persistent non-filing marks the company as "ACTIVE non-compliant" and feeds the Registrar's suo-motu strike-off pipeline under Section 248. Once an STK-1 or STK-5 notice issues, restoring the company is a National Company Law Tribunal matter — far more expensive and slower than a ₹19,000 amnesty filing would have been.
Step-by-step: what to do before 15 July 2026
- Pull your master data today. Log in to MCA21 v3 and check the company's filing history for every financial year since incorporation. Identify each pending AOC-4, MGT-7/MGT-7A, and ADT-1. Do this now — the portal was under strain after the MCA Data Centre incident on 5 June 2026, and last-minute load before 15 July will be heavy.
- Reconcile the financials that must accompany AOC-4. You cannot file AOC-4 without audited financial statements and the board's/auditor's reports for that year. If audits are pending, brief your auditor immediately — this is the step most likely to run past the deadline.
- Compute the CCFS fee. Calculate normal fee (based on authorised capital) plus 10% of the accrued additional fee for each form. Confirm the reduced computation reflects on the V3 challan before paying.
- File AOC-4 first, then MGT-7. Sequence matters because MGT-7 references the financials. Complete the embedded CSR-2 within AOC-4 if CSR applies.
- If the company is genuinely inactive, use the alternate reliefs. CCFS-2026 also lets you obtain dormant status under Section 455 via Form MSC-1 at half the normal filing fee, or apply for strike-off via Form STK-2 at 25% of the normal fee. For a company you no longer need, a clean STK-2 exit now is far cheaper than years of accruing default.
- Separately, file DPT-3 by 31 July 2026. The return of deposits due date was extended from 30 June to 31 July 2026 via General Circular No. 02/2026 dated 19 June 2026. This is a different deadline from CCFS — do not conflate them.
- Keep every challan and SRN. Retain proof of each filing and payment as your record of immunity under the scheme.
FAQ
Does CCFS-2026 apply to my company if only one year's filing is pending?
Yes. There is no minimum default. Even a single overdue AOC-4 or MGT-7 qualifies for the 90% additional-fee waiver if filed on the V3 portal on or before 15 July 2026.
Will the deadline be extended again?
Do not plan around an extension. The DPT-3 date moved for a specific reason (the June portal disruption), but the CCFS window has been fixed at 15 July 2026 since the February circular. Treat it as final and file early.
Does the scheme remove my liability under Section 164 disqualification?
Filing your pending returns under CCFS clears the defaults that feed the three-consecutive-year trigger, which is the point — you file before the disqualification crystallises. If you are already past three years of non-filing, get professional advice immediately; the scheme is your cleanest available route.
Can I use CCFS to shut down a company I never operated?
Yes — that is what the STK-2 option at 25% of normal fee is for. A never-active shell can be struck off cheaply under the scheme rather than left to accrue penalties and disqualification risk.
Is the 10% calculated on the additional fee only, or on everything?
Only on the additional (late) fee. You still pay the normal filing fee for each form in full — the concession applies exclusively to the ₹100/day accrued additional fee under Section 403. Confirm the reduced figure on the V3 challan before you pay, and raise a ticket immediately if the portal computes the full additional fee instead.
Does CCFS-2026 cover LLP filings like Form 8 and Form 11?
No. CCFS-2026 is a Companies Act scheme covering company forms (AOC-4 series, MGT-7/7A, ADT-1, FC-3, FC-4 and the 1956 Act equivalents). LLP annual filings run on a separate track and are not part of this circular, so do not assume your LLP defaults are covered here.
Closing
CCFS-2026 is the least expensive way you will ever clear pending ROC filings, and the door closes on 15 July 2026. For a compliance audit of your company — pending filings, penalty exposure, and the fastest route to clean status before the deadline — visit pvtltd.co.
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