MCA 2026 Amnesty Scheme: 90% Additional Fee Waiver for Company Corrections and CCFS Filings

You registered a private limited company in India - maybe for a startup idea, a side project, or a future business plan. Then life happened, and the company sat unused. Every year you missed filing your Annual Return (MGT-7) or Financial Statements (AOC-4), the government added a late fee of Rs. 100 per day per form to your outstanding tab - with no cap and no ceiling. For a company that has not filed for three or four years, this penalty backlog can run into several lakhs of rupees.

If you have been searching for how to close your private limited company, get a waiver of penalties for non-filing, activate your dormant company, or simply wind up an unused entity without a massive financial hit - the Ministry of Corporate Affairs (MCA) has just opened the door. The Companies Compliance Facilitation Scheme 2026 (CCFS 2026) is a one-time, strictly time-limited MCA amnesty scheme that slashes accumulated late fees by 90% and provides conditional immunity from penalty proceedings.

This guide explains everything you need to know: what CCFS 2026 is, who qualifies, how much you save, which forms are covered, how to close or pause your company legally, and what happens if you miss the 15th July 2026 deadline.

What Is the Companies Compliance Facilitation Scheme 2026?

The Companies Compliance Facilitation Scheme 2026 is a one-time MCA amnesty introduced vide General Circular No. 01/2026 dated 24th February 2026, exercising powers under Sections 460 and 403 of the Companies Act, 2013 read with the Companies (Registration Offices and Fees) Rules, 2014.

Under the normal provisions of Section 403, delayed filing of annual returns and financial statements attracts an additional fee of Rs. 100 per day per form - with no upper limit. Over multiple years of default, this has pushed hundreds of thousands of companies - particularly MSMEs, private limited companies, OPCs, and inactive startups - into a position where the penalty for not filing ROC returns has become financially unworkable. CCFS 2026 addresses this directly by offering a 90% waiver on accumulated additional fees and three structured exit or recovery pathways.

• Scheme Period: 15th April 2026 to 15th July 2026 (no extension expected)
• Governing Circular: General Circular No. 01/2026 dated 24th February 2026
• Legal Basis: Sections 403 and 460 of the Companies Act, 2013
• Applicable To: All company types under the Companies Act, 2013 and legacy Companies Act, 1956 forms
• Core Relief: Pay only 10% of accumulated additional (late) fees - a 90% waiver on ROC penalty liability
• Three Pathways: Regularise and continue; obtain dormant status; close company permanently via strike-off

Who Should Avail This Scheme?

CCFS 2026 is designed for companies that have accumulated filing defaults and need an affordable path to either fix, pause, or close their company. You should strongly consider this scheme if any of the following describes your situation:

• You incorporated a private limited company, OPC, or small company but never commenced business operations and never filed annual returns
• Your company was active for some years but has been inactive with no transactions and filings have lapsed for one or more years
• You want to close your company in India permanently and remove it from the MCA register at the lowest possible cost
• You want to wind up your private limited company or shut down a startup that never took off
• You want to put your company on hold - activate dormant status - rather than close it, so you can revive it later
• You have received a show-cause notice or adjudication notice from the Registrar of Companies (ROC) for non-filing of annual returns or financial statements
• Your accumulated late fee for non-filing is so large that normal compliance is unaffordable without the 90% waiver this scheme provides
• You are a director worried about disqualification under Section 164(2) of the Companies Act, 2013 due to the company's filing defaults
• You are an MSME, startup, or OPC with a compliance backlog and want to reset the company's MCA-21 record

How Much Can You Save Under CCFS 2026?

The financial relief under CCFS 2026 is substantial. Under normal provisions, the penalty for non-filing of annual returns accumulates at Rs. 100 per day per form with no ceiling. Most companies default on at least two forms per year - MGT-7 (Annual Return) and AOC-4 (Financial Statements) - making the actual daily penalty Rs. 200 per day across both forms. The table below shows the savings per form under the scheme:

Three Options: Close, Pause, or Fix Your Company

CCFS 2026 is not just a late-fee waiver - it is a structured compliance reset that gives you three clear pathways depending on what you want to do with your company. Whether you want to close your private limited company, activate dormant company status to preserve it, or simply regularise pending filings and continue operating, there is a specific route for you under this scheme.

Option 1: Fix Your Company - Regularise Pending Filings and Continue

If your company is operational or you intend to keep it active, this pathway lets you file all pending Annual Returns (MGT-7/MGT-7A) and Financial Statements (AOC-4) by paying only 10% of the accumulated additional fees. Once filed and accepted, your company's compliance record on MCA-21 is updated, the penalty for non-filing is waived at 90%, and the company returns to full good standing. This is the right route if you plan to continue the business, seek bank loans or funding, bid for government tenders, or enter formal contracts where compliance status is verified.

Option 2: Pause Your Company - Declare It Dormant (Section 455)

If your company is currently inactive but you do not want to shut it down permanently - perhaps you want to protect the company name, preserve its CIN, or revive it for a future project - you can activate dormant company status under Section 455 of the Companies Act, 2013 by filing Form MSC-1. Under CCFS 2026, the MSC-1 filing fee is only 50% of the normal fee. A dormant company stays on the MCA register, is protected from compulsory strike-off, and only needs to file one simplified form annually (MSC-3) to maintain its status. This is the lowest-compliance option for keeping an inactive entity alive without closing it. To reactivate a dormant company in the future, an application under Form MSC-4 can be filed with the ROC.

Option 3: Close Your Company - Voluntary Strike-Off (Permanent Closure)

If you have no plans to use the company and want a clean, permanent exit, you can close your private limited company by filing for voluntary strike-off using Form STK-2 during the scheme period. The filing fee under CCFS 2026 is only 25% of the normal STK-2 fee. Once the Registrar strikes off the company, it is permanently removed from the MCA register, ceases to exist as a legal entity, and all future compliance obligations are eliminated. This is the most cost-effective way to wind up a private limited company or shut down an unused startup - no court involvement, no winding-up proceedings, just a clean administrative closure.

Forms Covered Under CCFS 2026

The scheme covers a comprehensive list of annual compliance forms - both under the current Companies Act, 2013 and legacy forms from the Companies Act, 1956. This means even companies with very old compliance backlogs - dating back to 2010 and earlier - are eligible to regularise all historical defaults under CCFS 2026 with a single waiver of penalties for non-filing.

Forms Under the Companies Act, 2013

• MGT-7 - Annual Return (for all companies other than OPCs and small companies)
• MGT-7A - Annual Return for One Person Companies (OPCs) and Small Companies
• AOC-4 - Financial Statements (Balance Sheet and Profit & Loss Account)
• AOC-4 CFS - Consolidated Financial Statements
• AOC-4 NBFC (Ind AS) - Financial Statements for Non-Banking Financial Companies under Ind AS
• AOC-4 CFS NBFC (Ind AS) - Consolidated Financial Statements for NBFCs under Ind AS
• AOC-4 (XBRL) - Financial Statements in XBRL format
• ADT-1 - Intimation of Appointment or Change of Auditor
• FC-3 - Annual Accounts of a Foreign Company having a place of business in India
• FC-4 - Annual Return of a Foreign Company

Legacy Forms Under the Companies Act, 1956

• Form 20B - Annual Return (for companies with share capital)
• Form 21A - Annual Return (for companies without share capital)
• Form 23AC - Filing of Balance Sheet
• Form 23ACA - Filing of Profit and Loss Account
• Form 23AC-XBRL - Balance Sheet in XBRL format
• Form 23ACA-XBRL - Profit and Loss Account in XBRL format
• Form 66 - Compliance Certificate from a Company Secretary
• Form 23B - Intimation of Appointment of Statutory Auditor

Immunity from Penalty Proceedings

Beyond the 90% waiver on additional fees, one of the most valuable protections CCFS 2026 provides is a conditional immunity framework from penalty proceedings under Sections 92 and 137 of the Companies Act, 2013. Non-filing of annual returns and financial statements are statutory offences under these sections, which can result in prosecution of the company and personal liability for its directors. The immunity available depends entirely on when you act:

If No Notice Has Been Issued

If you file all required forms under the scheme before any notice is issued by the adjudicating officer, no penalty proceedings will be initiated under Sections 92 or 137 and the matter is treated as fully and finally resolved. This is the cleanest and most complete protection available - and the strongest reason to act early rather than wait for a notice to land.

If You Have Received a Show-Cause Notice

If a show-cause notice has already been issued but no adjudication order has yet been passed, filing the required forms within 30 days of receiving the notice will result in the penalty proceedings being concluded without any penalty being levied. As soon as you receive any ROC notice for non-filing of annual return, contact IncorpX immediately - the 30-day immunity clock starts from the date of receipt.

If an Adjudication Order Has Already Been Passed

If an adjudication order imposing a monetary penalty has already been passed and the 30-day window has elapsed, that specific penalty liability remains unaffected. CCFS 2026 does not provide retroactive relief against adjudication orders already issued. The scheme can still help you regularise filings going forward, but the past adjudicated penalty must be paid separately.

Immunity for ADT-1, FC-3, FC-4 and Legacy Forms

For forms such as ADT-1, FC-3, FC-4 and legacy forms under the Companies Act, 1956, immunity against prospective penal action is available provided no prosecution has been initiated prior to filing under the scheme. This forward-looking shield protects against future proceedings for these specific forms.

Who Cannot Use This Scheme?

CCFS 2026 is broadly applicable but has specific exclusions. A preliminary eligibility check is essential before initiating any filing, as an ineligible company cannot avail the fee concession and any incorrect filing wastes time and money. The following categories of companies are excluded from CCFS 2026:

• Companies against which a final notice for compulsory strike-off under Section 248 of the Companies Act, 2013 has already been issued by the Registrar
• Companies that have already filed a voluntary strike-off application (STK-2) with the Registrar before the scheme period
• Companies that had already applied for dormant status (MSC-1) before the scheme was announced
• Companies that have been dissolved pursuant to an amalgamation or merger under the Companies Act
• Vanishing companies as identified and listed by SEBI or MCA

All other company types - private limited, public limited, OPC, small company, MSME, startup, listed company, foreign company - are eligible. If your company falls into one of the excluded categories, IncorpX can advise on alternative compliance and closure mechanisms available to you.

What Happens If You Do Nothing?

Choosing to ignore CCFS 2026 and allowing the 15th July 2026 deadline to pass without action carries serious, escalating consequences. These are not theoretical - they are active enforcement mechanisms under the Companies Act, 2013 that will apply with full force the moment the scheme closes:

• Full ROC late fees resume immediately: From 16th July 2026, the Rs. 100 per day per form additional fee continues to accumulate with no cap. Every day of inaction makes your penalty for non-filing larger and more expensive to resolve.
• ROC enforcement and prosecution: MCA has explicitly stated in the circular that Registrars will initiate action against non-compliant companies after the scheme closes - including show-cause notices, adjudication orders, prosecutions under Sections 92 and 137, and compulsory strike-off proceedings under Section 248.
• Director disqualification under Section 164(2): If a company defaults on filing annual returns for three consecutive financial years, all directors are automatically disqualified for 5 years - barred from being appointed or continuing as directors in any company in India. This is career-impacting and applies to all directors of the defaulting company.
• Loss of control over company closure: A compulsory strike-off by the Registrar is far more difficult to deal with than a voluntary one under CCFS 2026. You lose the ability to manage the process on your terms, and outstanding liabilities and assets may be dealt with by the government.
• Damaged creditworthiness and business reputation: Non-compliant companies are flagged on MCA-21. This directly affects the ability to obtain bank loans, open or maintain bank accounts, participate in government tenders, and enter formal contracts with enterprises that conduct MCA due diligence.

Step-by-Step Process to Avail CCFS 2026

Availing CCFS 2026 follows a structured process. While MCA-21 accepts the filings directly, accurate document preparation, fee calculation, and correct form selection are critical to avoid rejection. Here is the complete process:

1. Identify all pending filings: Review your company's MCA-21 master data and filing history to identify every form that was due but not filed, along with the precise dates of default for each financial year.
2. Calculate your total fee exposure: For each overdue form, calculate the number of default days and multiply by Rs. 100 to arrive at the normal additional fee. Under CCFS 2026 you pay 10% of this amount, plus the standard government filing fee in full.
3. Choose your pathway: Decide whether to regularise and continue (MGT-7/AOC-4 filings), apply for dormant company status (MSC-1), or permanently close your company via strike-off (STK-2). Each pathway has different documents, fees, and timelines.
4. Prepare required documents: Depending on the chosen forms, documents typically include financial statements certified by a Chartered Accountant, director KYC documents, board resolutions, and registered office proofs.
5. File on MCA-21 within the scheme window: All filings must be submitted and fees paid between 15th April 2026 and 15th July 2026. Filings submitted after this date will not receive the CCFS 2026 concession and the full ROC late fee structure resumes.
6. Track filing status and secure acknowledgements: Monitor the SRN status of every filed form on MCA-21 and retain all SRN acknowledgements and payment receipts as documentary proof of compliance.

Compliance Requirements After CCFS 2026

Once you have availed CCFS 2026, your company's ongoing obligations depend on the pathway you chose. The table below summarises what each route requires going forward:

CCFS 2026 Quick Reference

The table below provides a complete at-a-glance summary of the Companies Compliance Facilitation Scheme 2026:

Why Act Through IncorpX?

At IncorpX, we have helped hundreds of founders, MSMEs, and businesses across India navigate MCA compliance - from clearing annual return backlogs and responding to ROC notices to closing private limited companies and obtaining dormant company status. CCFS 2026 requires careful eligibility assessment, accurate fee calculation, correct form selection, and error-free filing on MCA-21. Here is what you get when you work with us:

• Free eligibility check: We verify whether your company qualifies for CCFS 2026 and which forms are outstanding - before any process begins
• Precise fee calculation: We pull your company's complete MCA filing history and calculate the exact additional fee payable under the scheme for every defaulted form, so you know the total cost upfront
• End-to-end filing management: Our team of qualified Company Secretaries and Chartered Accountants prepares all documents, files on MCA-21, and tracks every submission through to completion
• Route advisory: We assess your specific situation - whether to close your company, activate dormant status, or regularise and continue - and recommend the most cost-effective, legally sound path for you
• Priority processing for STK-2 (company closure): Voluntary strike-off takes 2 to 4 months to complete. We begin processing immediately after 15th April 2026 to ensure your company closure is completed before the scheme closes
• ROC notice handling: If you have already received a show-cause or adjudication notice for non-filing, we respond on your behalf and ensure all filings are completed within the 30-day immunity window
• Post-filing support: We track your SRN status, handle any Registrar queries, and provide all acknowledgements and confirmation documents once filings are accepted
• Transparent flat-fee pricing: You know exactly what you will pay before we begin - no hidden charges, no surprises, no percentage-based billing

Conclusion

The Companies Compliance Facilitation Scheme 2026 is one of the most significant MCA compliance relief measures introduced in years. It is not a routine deadline extension or minor fee concession - it is a genuine one-time opportunity to resolve years of ROC default, get a 90% waiver on accumulated penalties for non-filing, and choose exactly what you want to do with your company: fix it, pause it, or close it.

For founders who registered a private limited company and never started operations, CCFS 2026 is the most affordable path to finally close the company, put it in dormant status, or regularise the compliance backlog - without the looming threat of director disqualification or ROC prosecution.

For companies that are active but behind on filings, this is the moment to reset the compliance record, waive the accumulated penalty for non-filing, and rebuild the company's MCA-21 standing at a fraction of the normal cost.

The window is open from 15th April 2026 to 15th July 2026. At IncorpX, we are ready to assess your company's position, calculate your exact savings, and complete every filing well before the deadline. The cost of doing nothing after 15th July will always be higher than the cost of acting today.