CCFS-2026 Closes on 31 August 2026: What Companies With Pending ROC Filings Need to Decide Now

Created On: August 11, 2026
Article, Global

Modified On: August 11, 2026

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Summary

The Companies Compliance Facilitation Scheme (CCFS) 2026 allows eligible companies to clear overdue annual filings by 31 August 2026 at the normal statutory fee plus 10% of the accumulated additional fee for delayed filing. The scheme covers specified company filings i.e. AOC-4, MGT-7/7A, ADT-1 can be mentioned to get reader’s attention but does not apply to LLP Form 8 or Form 11, making separate compliance action necessary for LLPs. Companies should act before the deadline to reduce additional fees and potentially benefit from immunity, while also avoiding risks such as director disqualification and strike-off proceedings. Businesses must decide whether to regularise, apply for dormant status, or pursue strike-off, depending on the company’s future purpose and value.

Because pending audits and financial statements can delay filings, companies should begin the process early and assess their eligibility and compliance position before 31 August 2026.

What Is CCFS-2026?

CCFS stands for Companies Compliance Facilitation Scheme.

CCFS-2026 is a one-time relief initiative introduced for companies registered under the Companies Act, 2013. It provides businesses with an opportunity to regularise overdue statutory filings with the Registrar of Companies (ROC) at a significantly reduced cost. Companies that have pending filings such as AOC-4, MGT-7, MGT-7A, or ADT-1 for one or more financial years can use the scheme to clear their compliance backlog and bring their records up to date.

The Companies Compliance Facilitation Scheme, 2026 closes on 31 August 2026. Companies carrying overdue annual filings can regularise them by paying the normal statutory fee plus 10 per cent of the accumulated additional fee. After that date, the full additional fee applies, and the Ministry of Corporate Affairs has signalled that Registrars will initiate action against companies still in default.

The scheme in summary

Element	Details
Introduced by	General Circular No. 01/2026 dated 24 February 2026
Statutory basis	Section 460 read with Section 403, Companies Act, 2013
Original window	15 April 2026 to 15 July 2026
Extended to	31 August 2026, by General Circular No. 03/2026 dated 8 July 2026
Reason for extension	Capacity restoration at the MCA data centre following a fire on 5 June 2026
Core concession	Normal fee plus 10 per cent of the applicable additional fee
Alternative routes	Dormant status under MSC-1 at reduced fee, voluntary strike-off under STK-2 at reduced fee

The extension was operational rather than discretionary. It responded to portal capacity constraints, not to representations for more time, which is a material difference for companies assuming a further extension will follow.

Which filings the scheme covers

Covered	Not covered
MGT-7 and MGT-7A AOC-4, AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC (Ind AS) ADT-1	LLP Form 11 LLP Form 8 Any other filing under the LLP Act, 2008 FC-3 and FC-4 for foreign companies Corresponding forms under the Companies Act, 1956

The LLP exclusion is the single most misreported feature of this scheme. Content circulating online suggests that LLPs can regularise Form 8 and Form 11 under CCFS-2026. They cannot. LLP additional fees continue to accrue under the multiplier structure introduced by the LLP (Amendment) Rules, 2022, and no LLP settlement scheme is currently in force.

Groups holding a mix of private limited companies and LLPs should therefore expect a split outcome. The company entities can be regularised at a concession. The LLP entities cannot, and their arrears should be assessed separately.

What the concession is worth

Additional fees on company annual filing forms accrue at Rs 100 per day per form with no upper limit. The arithmetic compounds quickly across multiple forms and multiple years.

Scenario	Forms pending	Approximate delay	Full Additional fee*	Under CCFS-2026*
One year of default	AOC-4 and MGT-7	300 days each	Rs 60,000	Rs 6,000
Two years of default	AOC-4 and MGT-7 for each year	300 and 665 days	Rs 1,93,000	Rs 19,300
Three years of default	AOC-4 and MGT-7 for each year	300, 665 and 1,030 days	Rs 3,99,000	Rs 39,900

*Figures are illustrative and calculated on the Rs 100 per day additional fee alone. Actual amounts depend on the number of forms, the exact delay in each case and the normal statutory fee applicable to the company’s authorised capital. The normal fee is payable in full in every case and is not discounted.

The concession applies only to the additional fee component. It does not touch the normal filing fee, and it does not by itself resolve the separate statutory penalties under Section 92(5) and Section 137(3), which are adjudicated separately.

The immunity condition, and why timing matters

The scheme offers immunity from prosecution in relation to the delay in filing the forms, provided the filing is completed before any adjudication notice has been issued, or within the prescribed period after one has been issued.

That condition rewards companies that act before the Registrar does. A company that has already received a show-cause notice is in a different position from one that has not, and the two require different handling. Any company uncertain about its notice position should check its MCA correspondence and the registered office address of record before relying on immunity provisions.

What happens after 31 August 2026

The circular states that Registrars will initiate action against companies remaining in default at the close of the scheme. In practice that means three exposures.

Additional fees revert to the full rate, retrospectively across the entire delay period. A filing made after the scheme closes will lose the 90% concession on additional fees and will therefore generally carry a substantially higher additional fee burden.

Director disqualification under Section 164(2)(a) becomes a live risk for any company that has not filed financial statements or annual returns for three continuous financial years. The disqualification runs for five years and attaches to every directorship the individual holds, not only to the defaulting company. Directors of otherwise compliant group entities are exposed through a single dormant company that nobody attended to.

Strike-off proceedings under Section 248 follow for entities that remain in sustained default. Restoration through the National Company Law Tribunal is possible but slow and considerably more expensive than the filing that was avoided.

Three decisions to make before the deadline

Companies with pending filings face a choice between three routes, and the right one depends on whether the entity has a future.

Regularise and continue. Appropriate where the company is trading, or holds assets, contracts, licences or a name worth retaining. Requires audited financial statements for every pending year, which is the constraint that most often makes the deadline unreachable if work starts too late.

Apply for dormant status. Appropriate where the company is not trading but is being retained deliberately, to hold a name, a licence or a registered structure. Filed through MSC-1 under Section 455 at a reduced fee under the scheme.

Close the company. Appropriate where the entity serves no purpose and is generating compliance cost and director risk with no offsetting benefit. Filed through STK-2 at a reduced fee under the scheme.

The third option is the one most often deferred and most often regretted. A dormant subsidiary that nobody has looked at since incorporation is a live disqualification risk for every director on its board.

The practical constraint

The binding constraint on using this scheme is rarely the filing itself. It is the audited financial statements for the pending years, which must exist before AOC-4 can be filed, and which require a signed auditor’s report. Where no auditor was appointed for those years, ADT-1 has to be regularised first.

Companies starting this exercise in mid-August should expect the audit preparation, not the MCA submission, to determine whether the deadline is met.

How IMC can help

At IMC, India corporate secretarial team assesses CCFS-2026 eligibility, reconstructs statutory registers and financial records for backlog years, coordinates the audit work required before AOC-4 can be filed, and completes the filings on the MCA V3 portal. The team also advises on whether regularisation, dormancy or strike-off is the appropriate route for each entity in a group.

For companies operating across the India, UAE and Singapore corridor, the same team handles the corresponding obligations in each jurisdiction.

Further detail on the underlying obligations is set out on the annual return filing of a company in India

Frequently Asked Questions

When does CCFS-2026 close?

The scheme closes on 31 August 2026. It was originally due to close on 15 July 2026 and was extended through General Circular No. 03/2026 dated 8 July 2026.

What does the 90 per cent waiver actually cover?

It reduces the additional fee payable on delayed filings to 10 per cent of the amount that would otherwise apply. The normal statutory filing fee remains payable in full.

Can an LLP use CCFS-2026 to clear pending Form 8 and Form 11 filings?

No. The scheme applies to filings under the Companies Act. LLP filings are governed by the LLP Act, 2008 and fall outside it. No LLP settlement scheme is currently in force.

Does the scheme apply to foreign companies with a place of business in India?

Yes. Forms FC-3 and FC-4 are within the scope of the scheme.

What happens if a company files on 1 September 2026 instead?

The full additional fee applies, calculated across the entire period of delay at Rs 100 per day per form, with no concession.

Does the scheme remove the penalty under Section 92 or Section 137?

The scheme provides immunity from prosecution in relation to the delay where the filing is completed before an adjudication notice is issued, or within the prescribed period after one. Companies that have already received a notice should take advice on their specific position.

What is required before a company can file overdue AOC-4 forms?

Audited financial statements for each pending year, with a signed auditor’s report. Where no auditor was appointed for those years, the auditor appointment must be regularised through ADT-1 first.

Author Bio:

Shriya Mandal is a corporate compliance professional with expertise in FEMA regulations and cross-border compliance matters, including ECB, FC-GPR, FC-TRS, and FDI reporting for companies and LLPs. Her areas of practice include capital raising through rights issues and CCD issuances, post-incorporation compliances, NBFC-related RBI filings, and corporate secretarial work. She also advises on board governance, preparation of resolutions, statutory records, and annual return filings.

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