MCA Update on Pending Statutory Filings CCFS 2026

On  24 February 2026, The Ministry of Corporate Affairs (MCA) has introduced a scheme called CCFS-2026 (Company Compliance Fresh Start Scheme 2026)

If your company in India has pending ROC filings, unpaid additional fees, or compliance delays, this update is important for you. The government is giving companies a fresh chance to clear pending annual returns and financial

Table of Contents

What is CCFS 2026?

CCFS refers to the Company Compliance Fresh Start Scheme
It is a special relief scheme for all companies incorporated in India, which provides them a one-time opportunity to file their pending ROC filings at a lower cost and without the penalties that were earlier levied for non-compliance.

It is designed to help businesses that have fallen behind on their paperwork.

Essentially, it gives companies three different “exit paths” or ways to clean up their records at a massive discount.

Scheme Period – Important Dates

You need to understand that this Scheme is available for a limited period, and companies must comply with it as soon as possible.

CCFS scheme is available only during the following window:15 April 2026 to 15 July 2026

This means companies have three months to complete pending filings and avail themselves of the benefits. After this period ends, normal additional fees and penalties will apply again.

Time-bound compliance planning is therefore critical.

Do it early and file quickly, and if you need any assistance, we are here to help you!

Why is the CCFS 2026 Beneficial for Companies?

Here in this section, we will cover all the major benefits covered under the CCFS scheme and how it is going to help the companies in India:

Benefits Which companies need to follow this scheme? What do companies need to do?
The “Catch-Up” Option If a company is still active but just late on its annual paperwork, it can use this Scheme to get back on track.

The Benefit: Instead of paying the full penalty for being late, they only have to pay 10% of the usual late fees. It’s basically a 90% discount on fines.

 Companies can file their:

  • Annual Returns (Section 92)
  • Financial Statements (Section 137)
The “Sleep” Option (Dormant Status) If a company isn’t doing any business right now but doesn’t want to close down permanently, they can apply for “Dormant” status. They can file a form called MSC by paying  50% of the normal filing fee
The “Close Down” Option (Strike Off) If the owners want to shut the company down for good because it’s no longer needed, they can choose to have it “struck off” the register. They filed form STK-2. During this special scheme period, you only have to pay 25% of the standard filing fees to close the business.

How penalties changed (Earlier Vs Now)

In this section, we will explain how the penalty structure has changed under the CCFS Scheme, what the penalties were earlier, and what has been revised now.

Type of Cost Regular/Previous Penalty Under the CCFS Scheme
Massive Waiver of “Per Day” Fines/ Late Filing Fine ₹100 per day (No limit) You only pay 10% of that total penalty.
Closing a Company Full Filing Fee (Expensive) 75% Discount (Pay 25%)
Dormant Status Full Application Fee 50% Discount

What are the forms covered under CCFS?

The Scheme applies to a wide range of ROC forms from both the 2013 and 1956 Companies Acts. Here is the list of forms covered under this Scheme that can be filed even if there are pending penalties or other compliance issues:

MGT-7,

MGT-7A,

AOC-4,

AOC-4 CFS,

AOC-4 NBFC (Ind AS),

AOC-4 CFS NBFC (Ind AS),

AOC4 (XBRL),

ADT-1,

FC-3,

FC-4

Form 20B,

Form 21A,

Form 23AC,

Form 23ACA,

Form 23AC-XBRL,

Form 23ACA-XBRL,

Form 66

Form 23B

Which Companies are excluded under CCFS Scheme?

Although all companies registered under the Companies Act are generally eligible for this Scheme, certain categories of companies mentioned in the update are not eligible. Let’s understand these categories.

  • Forced Closures: Companies that have already received a final notice from the Registrar to be “struck off” (removed)
  • Already Applied: Companies that had already applied to be struck off or to become “dormant” before this Scheme started
  • Amalgamated/Dissolved: Companies that have already been dissolved through a merger or amalgamation
  • “Vanishing Companies”: Companies that have disappeared or stopped communicating with authorities entirely

Immunity Rules for CCFS Scheme

This Scheme outlines how a company can get immunity from penalties and legal action if it catches up on its paperwork right now. Let’s understand these:

1. Immunity for Financial Statements and Annual Returns

If a company has failed to file its Annual Returns (Section 92) or Financial Statements (Section 137), it can avoid penalties if it files them under this Scheme, provided:

  • They file before the government sends them a formal notice.
  • OR they file within 30 days after receiving a notice.

In short:  If the 30-day window has already passed, or if a judge has already ordered the company to pay a fine, this Scheme won’t help. The company still has to pay the original penalty.

2. Immunity for Other Specific Forms

The document lists several specific e-forms (like ADT-1, Form 20B, etc.) that deal with auditors and other corporate updates. You get immunity from future legal action on these if:

  • You file them during this specific Scheme period.
  • The government hasn’t already started a court case or sent you a formal “show cause notice” (a letter asking why they shouldn’t punish you) before you filed.

3. “Use It or Lose It.”

This is a clear warning. Once this Scheme ends, the Registrars of Companies will take strict action against companies that did not use this grace period.

The government is giving a limited-time chance to clear past mistakes. If you have missed any filings, complete them now to avoid heavy fines and legal trouble. But this option is available only if the authorities have not already issued a final penalty against you.

What do companies need to know?

Companies must understand that ignoring this Scheme means exposing themselves to additional fines and legal consequences in the coming years. Since this Scheme is available only for a limited time, failure to act now can result in serious compliance risks.

If companies do not take corrective action:

  • Full penalties will be imposed
  • Directors may face disqualification
  • The risk of prosecution will continue
  • Banking and funding opportunities may be affected
  • The company’s reputation may suffer

CCFS is a temporary relief measure — not a permanent solution. Companies should use this opportunity before the compliance window closes.

Case Study for Indian Companies Following CCFS Scheme:

XYZ Private Limited, a small trading company, failed to file its Annual Return (MGT-7) and Financial Statements (AOC-4) for over 400 days due to internal delays. Under normal rules, the penalty of ₹100 per day per form had grown to nearly ₹80,000. The company also faced the risk of director disqualification and possible legal action.

When the CCFS 2026 Scheme was introduced, the company used the “Catch-Up” option and filed all pending forms during the scheme period. Instead of paying the full penalty, they paid only 10% of the total late fees, saving more than ₹70,000. Their compliance status was restored, and they avoided prosecution.

This example clearly shows that if businesses act within the CCFS 2026 window, they can significantly reduce penalties and protect their company from serious legal consequences.

Conclusion

If you have missed previous filings or any particular ROC form (mentioned in the document) and do not want to delay any further, this is the final and a great opportunity to act now and complete them at the earliest.

It is always better to complete your pending filings on time. You can take the help of a CA or CS to ensure that all compliances are completed correctly, with the applicable reduced penalties and in accordance with current regulations.

How can Mercurius help?

At Mercurius, with over 17 years of professional experience in ROC compliance, company law advisory, and corporate restructuring, we assist businesses in:

  • Identifying pending filings
  • Preparing financial statements
  • Filing ROC forms accurately
  • Applying for Dormant Status
  • Managing the strike-off process
  • Ensuring immunity compliance

Our team of CAs, CS, and compliance experts ensures your company uses CCFS 2026 effectively and safely. If your company in India has pending ROC filings, now is the right time to act.

Let this be your compliance fresh start.