[Analysis] CCFS 2026 | MCA Scheme to Clear Pending Company Filings

Companies Compliance Facilitation Scheme 2026 (CCFS-2026) is a one-time compliance window introduced by the Ministry of Corporate Affairs (MCA) vide General Circular No. 01/2026 dated February 24, 2026, under the powers conferred by section 460 read with section 403 of the Companies Act, 2013. The scheme is operational from April 15, 2026, to July 15, 2026, and allows defaulting companies to regularise their long-pending statutory filings — including annual returns and financial statements — by paying only 10% of the total additional fees otherwise applicable. Beyond fee relief, the scheme also offers inactive or defunct companies a structured pathway to either obtain dormant status under section 455 by filing e-form MSC-1 at 50% of the normal fee, or to apply for voluntary strike-off via e-form STK-2 at just 25% of the applicable filing fees. The primary objective of CCFS-2026 is not merely to condone past defaults but to drive proactive compliance, clean up the MCA-21 corporate registry, and establish long-term regulatory discipline — marking a clear policy shift from the earlier settlement-based approach under the Company Law Settlement Scheme (CLSS) to a compliance-facilitation framework.

Table of Contents

1. Introduction
2. Background – Why CCFS Matters?
3. Options Available to Companies Under CCFS
4. What Makes CCFS 2026 Different from Past Schemes?
5. Period of Operation of CCFS
6. Applicability of the Scheme
7. What Forms are Covered Under the Scheme?
8. Core Benefit Under the Scheme – Reduction in Additional Fees
9. Additional Compliance Pathways Under the Scheme
10. Immunity from Penalty Proceedings
11. What if the Company Fails to File Pending Forms Under the Scheme?
12. Conclusion

1. Introduction

The MCA, through General Circular No. 01/2026 dated February 24, 2026, has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026). The scheme offers companies a one-time window to complete long-pending statutory filings at reduced additional fees.

Beyond the fee relief, the intent is to bring records up to date and improve overall compliance standards. It also enables inactive or defunct companies to move towards dormancy or strike-off at a lower cost, helping clean up and streamline the corporate registry.

2. Background – Why CCFS Matters?

The Companies Act, 2013, requires all companies to file their annual returns and financial statements. Fees for filing such statements, documents, returns, etc., are governed by section 403 of the Companies Act, 2013, read with the Companies (Registration Offices and Fees) Rules, 2014. With effect from July 1, 2018, delays in filing annual returns and financial statements attract an additional fee of Rs 100 per day, without any upper limit, often resulting in substantial financial liability for companies with long-pending defaults.

The Ministry has undertaken several initiatives to promote ease of doing business for corporates. However, the number of inactive companies has crossed the 20-lakh mark, and the Ministry has received representations from various stakeholders, including such companies, requesting a waiver of additional fees through a scheme.

To provide a one-time opportunity for companies to file their documents related to annual return and financial statements in the MCA-21 registry or to file for dormancy/closure, the Central Government, in exercise of powers under section 460 read with section 403 of the Companies Act, 2013, has decided to condone the delay in filing documents with the Registrar through a Scheme, namely the “Companies Compliance Facilitation Scheme, 2026”.

3. Options Available to Companies Under CCFS

Under the Scheme, companies/inactive companies have the option to:

• Get their pending annual filings completed by paying only 10% of the total additional fees payable on account of delays or
• Get their companies declared as ‘dormant company’ under section 455 of the Act by filing e-form MSC-1 and paying half of the normal fee payable under the rules.
• Get their companies struck off by filing an application in e-form STK-2 during the currency of the scheme by paying 25% of the filing fees.

4. What Makes CCFS 2026 Different from Past Schemes?

All earlier MCA amnesty initiatives were structured under the title “Company Law Settlement Scheme” (CLSS), which operates as a one-time settlement window that permits defaulting companies to regularise their pending filings by paying 25% of the applicable additional fees. The emphasis was on ‘settlement’, a curative mechanism designed to resolve past non-compliances.

However, the present scheme has been consciously titled the “Companies Compliance Facilitation Scheme” (CCFS). The shift in nomenclature is not merely cosmetic. It reflects a clear policy transition. The Government has moved from a settlement-based approach to a compliance-driven facilitation framework. The focus is no longer just on condoning past defaults, but on ensuring timely compliance and maintaining an accurate corporate registry.

The CCFS 2026 is also being projected as a one-time opportunity. Companies that do not regularise their defaults during this period should not assume that another similar window will follow. After the scheme closes, the normal penal and adjudication provisions under the Companies Act will apply in full force.

In furtherance of this objective, the financial barriers to voluntary exit have been significantly reduced. The strike-off filing fee has been reduced from Rs 10,000 to Rs 2,500, making closure a viable and economical option for defunct entities.

In essence, the evolution from ‘Settlement’ to ‘Compliance Facilitation’ signals a policy shift towards proactive governance, registry clean-up, stricter enforcement post-window and long-term regulatory discipline.

Comparison Table – CCFS 2026 vs. CLSS

Feature	Old Scheme (CLSS)	CCFS 2026
Scheme name	Company Law Settlement Scheme, 2014	Companies Compliance Facilitation Scheme, 2026
Nature	One-time settlement	Compliance facilitation
Eligibility	Defaulting companies with pending filings	All companies except the specified excluded categories
Scheme Period	15 Aug 2014 – 15 Oct 2014	15 April 2026 – 15 July 2026
Forms Covered	Limited set of annual filing and related forms	A wider list of forms is covered
Additional Fees Relief	Pay only 25% of the actual additional fee payable	Pay only 10% of the additional fee
Dormant status option	MSC-1 filing at 25% of the fee	MSC-1 filing at 50% of the fee
Strike-off option	FTE form at 25% fee	STK-2 form at 25% fee
Exceptions (Who cannot apply for the scheme)	Companies facing strike-off action, applied for strike-off/dormancy, and vanishing companies.	Companies facing strike-off action, companies that applied for strike-off/dormancy, companies that have vanished, and companies dissolved via amalgamation.

Comparison Table – CCFS 2026 vs. CODS 2018

Feature	CODS-2018	CCFS 2026
Scheme name	Condonation of Delay Scheme, 2018	Companies Compliance Facilitation Scheme, 2026
Eligibility	Defaulting companies that failed to file financial statements/annual returns for a continuous period of 3 years	All companies except for the specified exclusions.
Scheme Period	01 January 2018 – 31 March 2018	15 April 2026 – 15 July 2026
Exceptions (Who cannot apply for the scheme)	Companies that have been struck off/whose names have been removed from the ROC under section 248(5) of the Companies Act.	Companies facing strike-off action, companies that applied for strike-off/dormancy, companies that have vanished, and companies dissolved via amalgamation.
Additional Fees payable	Additional fee payable as per section 403 of the Companies Act, read with Companies (Registration Offices and Fee) Rules, 2014	Pay only 10% of the additional fee.
Dormant company option	Not provided	Allowed – MSC-1 at 50% of the normal filing fee
Strike-off Option	Not specifically provided	STK-2 permitted at 25% of the filing fee
Post-Scheme Consequence	DINs are deactivated on expiry of the scheme period	ROC to take action against non-compliant companies
Forms Covered	Limited scope (only specified overdue documents are allowed)	A wider list of forms is covered

5. Period of Operation of CCFS

The scheme shall be operational from 15.04.2026 to 15.07.2026.

6. Applicability of the Scheme

All companies are permitted to file relevant e-forms that were due for filing on any given date in accordance with the provisions of the Companies Compliance Facilitation Scheme, 2026, except for the following:

• Companies against which final notice for strike-off under section 248 of the Companies Act, 2013 (previously section 560 of the Companies Act, 1956) has already been initiated.
• Companies that have themselves filed a strike-off application.
• Companies that have applied for obtaining dormant status under section 455 of the Act before the scheme.
• Companies that have been dissolved pursuant to a scheme of amalgamation
• Vanishing companies[1]

7. What Forms are Covered Under the Scheme?

The Scheme applies to “relevant e-forms” relating to:

Companies Act, 2013 Forms

• MGT-7 – Annual Return
• MGT-7A – Annual Return (OPC and Small Company)
• AOC-4 – Financial Statements
• AOC-4 CFS – Consolidated Financial Statements
• AOC-4 NBFC (Ind AS) – Financial Statements
• AOC-4 CFS NBFC (Ind AS) – CFS
• AOC -4 (XBRL) – Financial Statements in XBRL
• ADT-1 – Appointment of Auditor
• FC – 3 – Annual Accounts (Foreign Company)
• FC – 4 – Annual Return (Foreign Company)

Legacy Forms under Companies Act, 1956

• Form 20B – Annual Return
• Form 21A – Annual Return (Small Company)
• Form 23AC – Balance Sheet
• Form 23ACA – Profit & Loss Account
• Form 23AC-XBRL – Balance Sheet (XBRL)
• Form 23ACA-XBRL – Profit & Loss Account (XBRL)
• Form 66 – Compliance Certificate
• Form 23B – Intimation of appointment of auditor

8. Core Benefit Under the Scheme – Reduction in Additional Fees

Every company must be required to pay the fees on the filing of each relevant e-form as per the following:

Type of Fees	Amount
Normal Fees	As prescribed under the Companies (Registration Offices and Fees) Rules, 2014
Additional Fees	Only 10% of the additional fees as prescribed under the Companies (Registration Offices and Fees) Rules, 2014

9. Additional Compliance Pathways Under the Scheme

Every company that files an application for obtaining the status of a ‘dormant company’ under section 455 in e-form MSC-1 must pay a fee of one-half of the normal filing fees applicable in this regard.

Further, every company that applies for striking off by filing e-form STK-2 must be required to pay only 25% of the applicable filing fees under the Companies (Removal of Name of Companies from the Registrar of Companies) Rules, 2016.

10. Immunity from Penalty Proceedings

The most valuable aspect of the scheme is the conditional immunity framework.

• Where No Adjudication Order is Passed – If filings are made before issuance of notice by the adjudicating authority or within 30 days of issuance of notice, then proceedings under section 92 or 137 shall be concluded, and no penalty shall be levied.
• Where an Adjudication Order is Already Passed – If the period of 30 days after issuance of notice for adjudication has expired or where the adjudication order imposing penalty for defaults under section 92 or 137 has already been passed, then liability to pay penalties remains unaffected.

Further, for forms such as ADT-1, FC-3, FC-4, and legacy forms, immunity from prospective penal action is available, provided no prosecution has been initiated before filing under the Scheme.

11. What if the Company Fails to File Pending Forms Under the Scheme?

The MCA has issued a clear warning. If the company remains non-compliant after the scheme window closes on 15 July 2026, the Registrars of Companies may exercise adjudication powers to take action against entities that have not availed themselves of the scheme, which could result in significant financial penalties.

12. Conclusion

The Companies Compliance Facilitation Scheme, 2026, shows a clear change in approach. Instead of giving repeated settlement windows, the Ministry is now pushing companies to get their filings up to date in a structured way. With additional fees capped at 10 per cent and lower fees for dormancy and strike-off, it provides genuine relief to companies seeking to clear old defaults.

At the same time, the window is open for only three months, and the message is clear: strict action will follow once it closes. The idea is to update the registry and improve compliance in the future.

Companies should treat this as a serious opportunity. It is a chance to correct past gaps, reduce future risk and decide whether to continue the company or close it properly.

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[1] An explanation to Rule 3 of the Companies (Removal of Names of Companies from the Register of Companies) Rules, 2016