If your company hasn’t filed its AOC-4 or MGT-7 for a year (or five), you already know the number that keeps climbing every time you check the MCA portal: additional fees at ₹100 per day, per form, with no upper limit. On a form that’s three years overdue, that alone can cross ₹1 lakh. Add the risk of your directors getting disqualified under Section 164(2), and “we’ll deal with it later” stops being a viable plan.
This is exactly the gap the Ministry of Corporate Affairs (MCA) is trying to close with the MCA Amnesty Scheme 2026, officially called the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026). It gives companies a one-time window to clear pending filings by paying only a fraction of the additional fee they’d normally owe.
In this guide, we’ll cover what the scheme actually offers, who can use it, the exact fee structure, the deadline (which has already been extended once), and what happens if a company lets the window close without acting.
What Is the MCA Amnesty Scheme (CCFS-2026)?
CCFS-2026 was introduced by the MCA through General Circular No. 01/2026, dated 24th February 2026, using powers granted under Sections 403 and 460 of the Companies Act, 2013. In plain terms, these sections let the government waive or reduce the additional fee that would otherwise apply to late filings.
The scheme is not a blanket pardon. It’s a structured, time-bound opportunity for companies that have fallen behind on statutory filings to:
- Regularise pending annual filings by paying only 10% of the additional fee.
- Apply for dormant company status at a reduced fee, if the company is genuinely inactive.
- Apply for voluntary strike-off at a reduced fee, if the company wants to close down instead.
Think of it as a reset button for companies whose compliance records have drifted out of shape — deliberately or through oversight — without pushing them straight into penalty and prosecution proceedings.
Why Did MCA Introduce This Scheme?
Since 1st July 2018, any delay in filing annual returns or financial statements has attracted an additional fee of 100 per day, per form, with no cap. Over several years, this has quietly become a serious burden for a specific group of companies: MSMEs, early-stage startups, OPCs, and small private companies that stopped operating or fell behind on paperwork without formally closing.
The MCA’s stated objectives with CCFS-2026 are to:
- Reduce the accumulated additional-fee burden on genuinely small and defaulting companies.
- Clean up the MCA-21 registry so it reflects accurate, current information.
- Give inactive companies a low-cost path to either go dormant or shut down properly, instead of sitting in default indefinitely.
This isn’t the first time MCA has done this. The Companies Fresh Start Scheme, 2020 (CFSS-2020), launched during the pandemic, offered a full fee waiver and blanket immunity from prosecution. CCFS-2026 takes a more measured approach – partial fee relief (10%, not 100%) paired with conditional immunity, rather than a complete write-off.
Scheme Period: When Does CCFS-2026 Close?
This is the part every business owner should pin to their calendar.
- Original window: 15th April 2026 to 15th July 2026
- Extended window: 15th April 2026 to 31st August 2026
The extension was notified through General Circular No. 03/2026, dated 8th July 2026, after a fire incident at the MCA data centre on 5th June 2026 disrupted MCA21 filing services during what should have been the peak filing period. All the original terms – the fee concessions, eligibility conditions, and immunity provisions – remain unchanged. Only the closing date moved.
That said, treat 31st August 2026 as a hard deadline, not a soft one. Portal disruptions of this kind tend to create last-minute traffic jams as the date approaches, and a further extension shouldn’t be assumed.
Who Can Avail the MCA Amnesty Scheme?
Broadly, all companies with pending statutory filings are eligible. The scheme excludes only a narrow set of cases:
- Companies against which MCA has already issued a final strike-off notice under Section 248.
- Companies that have already applied for strike-off on their own.
- Companies that had already applied for dormant status before the scheme began.
- Companies dissolved through a scheme of amalgamation.
- “Vanishing companies” (entities that raised funds and then went untraceable).
If your company doesn’t fall into any of these categories and has overdue annual filings sitting on the MCA portal, you’re eligible to use the scheme.
What Can You Do Under CCFS-2026?
The scheme offers three distinct paths, depending on where your company actually stands.
1. File Pending Annual Returns and Financial Statements
If your company is operational but behind on filings, you can file the overdue forms during the scheme window and pay only 10% of the additional fee that would otherwise apply. The normal filing fee still applies as usual — the concession is only on the penalty portion.
Forms covered include:
- MGT-7 / MGT-7A (Annual Return)
- AOC-4, AOC-4 XBRL, AOC-4 CFS, AOC-4 NBFC (Ind AS)
- ADT-1 (Auditor appointment)
- FC-3 and FC-4 (for foreign companies)
- Certain legacy Companies Act, 1956 forms (Form 20B, 21A, 23AC, 23ACA, 66, 23B)
2. Apply for Dormant Company Status
If your company isn’t doing business anymore but you’d rather not shut it down entirely, you can apply for dormant status under Section 455 by filing e-Form MSC-1, paying 50% of the normal filing fee. Dormant status keeps the company on the register with significantly reduced ongoing compliance.
3. Apply for Voluntary Strike-Off
If you want to close the company altogether, you can file e-Form STK-2 during the scheme period and pay only 25% of the normal filing fee prescribed for strike-off.
Fee Structure Summary Table
| What You’re Doing | Fee Payable |
| Normal filing fee (any form) | As prescribed under the Rules — no discount |
| Additional (late) fee for annual filings | Only 10% of the otherwise applicable additional fee |
| Application for dormant status (MSC-1) | 50% of the normal fee |
| Application for strike-off (STK-2) | 25% of the normal fee |
Quick Example: Say your company’s MGT-7 is 300 days overdue. At the standard rate of 100/day, the additional fee alone would normally be 30,000. Filed under CCFS-2026, that additional fee drops to 3,000 — a saving of 27,000 on that one form alone. For companies with three or four years of pending filings across multiple forms, the total savings can easily run into lakhs.
Does the Scheme Give Immunity From Penalty?
Partially, and the conditions matter.
For Annual Return (Section 92) and Financial Statements (Section 137): If you file under the scheme before the adjudicating officer issues a notice, or within 30 days of receiving one, the proceedings are closed and no penalty is levied. If an adjudication order has already been passed, or the 30-day window has lapsed, the penalty liability stays as it is — filing under the scheme doesn’t erase it after the fact.
For other forms (ADT-1, FC-3, FC-4, legacy forms): Immunity from future penal action applies as long as no prosecution has been launched and no show-cause notice issued before you file.
There’s no separate application needed for this immunity — filing the overdue form itself is sufficient.
One important exception: immunity does not extend to defaults under Section 96 (failure to hold an Annual General Meeting). However, companies can still hold AGMs for prior years, adopt the pending financial statements, and then use the scheme to regularise the related filings.
What Happens If You Miss the Deadline?
Once CCFS-2026 closes on 31st August 2026, things go back to the default rules — and they’re not gentle.
- Full additional fee resumes: 100 per day per form, uncapped, starting 1st September 2026.
- ROC enforcement action: Show-cause notices, adjudication under Sections 92 and 137, and prosecution become live options again.
- Director disqualification: Under Section 164(2), directors of companies that fail to file financial statements or annual returns for three consecutive financial years face a 5-year ban from holding any directorship.
- Compulsory strike-off: The Registrar can initiate strike-off under Section 248 — a far messier and less controlled process than applying for voluntary strike-off yourself.
- Reputational and financial cost: Non-compliant status on the MCA-21 registry can affect loan approvals, tender eligibility, and due diligence in any future funding or M&A conversation.
In short, missing this window doesn’t just mean paying more later — it can mean losing control over how and when the issue gets resolved.
Common Mistakes to Avoid
- Assuming the scheme waives the normal filing fee too. It doesn’t. The 10% concession applies only to the additional (late) fee, not the standard fee payable on any filing.
- Delaying because of the extension. The window has already been pushed once due to a genuine technical disruption. Treat 31st August 2026 as final.
- Filing without getting accounts audited first. For overdue AOC-4 filings, your financial statements still need to be properly audited with a valid UDIN before you can file — this step alone can take time if your books aren’t in order.
- Ignoring Section 96 defaults. If your AGMs are also pending, factor in the time needed to conduct them before assuming your filings are scheme-ready.
- Waiting for a “final push” reminder. Portal traffic tends to spike hard in the last week before a compliance deadline. Filing early avoids technical glitches at the worst possible time.
Frequently Asked Questions
Is the MCA Amnesty Scheme mandatory?
No, it’s entirely optional. It’s an opportunity to regularise pending filings at a lower cost — companies that don’t use it simply continue to owe the full additional fee.
What is the last date to avail CCFS-2026?
31st August 2026, following the extension granted via General Circular No. 03/2026.
Does the scheme reduce the normal MCA filing fee?
No. It only reduces the additional (delay) fee. The standard filing fee under the Companies (Registration Offices and Fees) Rules, 2014 still applies in full.
Can a company use the scheme for filings going back several years?
Yes, the scheme covers overdue annual filings regardless of how many years they’ve been pending, as long as the company isn’t in one of the excluded categories.
What if my company wants to shut down instead of filing overdue returns?
You can apply for strike-off using Form STK-2 at a 25% concessional fee. Depending on how long the company has been inactive, you may still need to file returns up to the year the company stopped operating, per the Companies (Removal of Names of Companies from the Register of Companies) Rules, 2016.
Will there be another extension after 31st August 2026?
There’s no indication of a further extension at this stage. Given that the last one was granted only because of a data-centre outage, companies shouldn’t plan around the assumption of more time.
Get Your Compliance Sorted Before the Window Closes
Sorting out years of pending MCA filings on your own — auditing old financial statements, calculating exact additional fees, conducting overdue AGMs, and filing everything correctly on the MCA V3 portal — is genuinely tedious, and mistakes can cost you the concessional fee altogether.
If you’d rather hand this off, Daily Filing can manage the entire CCFS-2026 process for your company — from identifying every pending form and calculating your exact savings, to coordinating the audit, filing the forms correctly, and confirming everything is closed out before 31st August 2026.
Need help clearing your pending ROC filings before the deadline? Contact Daily Filing today and get your compliance sorted the right way, the first time.
