The situation — how it starts
Vikram runs a trading company incorporated in 2019 out of Noida’s Sector 62. For the first two years everything was filed on time. Then 2021 hit — business contracted, his CA moved on, and somewhere between payroll and chasing receivables the AOC-4 and MGT-7 filings for FY 2020-21 simply did not happen. Then FY 2021-22 followed. Then FY 2022-23.
By early 2025, Vikram had three financial years of overdue annual filings sitting with the Registrar of Companies. Every time the thought surfaced, he opened the MCA portal, saw the late-fee counter — ₹100 per day, per form, no upper limit — and closed the tab. The number had reached a point that felt impossible to address.
As of 15 April 2026, Vikram’s situation has a name and a solution. CCFS 2026 is live, and the accumulated late fee — whatever it has grown to — is payable at just 10% under this scheme.
Why so many companies are still sitting on this
The additional fee for delayed annual filings is ₹100 per day, and AOC-4 (financial statements) and MGT-7 (annual return) attract this separately. A company that has missed both forms for three financial years has accumulated roughly ₹2.19 lakh — and that number is still running today.
The wrong reaction is to treat CCFS 2026 as one more reminder and deal with it next month. Two things make that expensive. First, the scheme has a hard end date — 15 July is not extendable; MCA explicitly stated no extension at issuance. Second, if an adjudication notice has already been issued against your company for a specific default, the immunity does not apply to the penalties under that notice. The discount only works if you file before a formal order is passed against you.
What CCFS 2026 actually covers
MCA introduced CCFS 2026 through General Circular No. 01/2026 dated 24 February 2026, deriving authority from Section 460 read with Section 403 of the Companies Act 2013.
| Company situation | What CCFS 2026 offers | Fee structure |
|---|---|---|
| Overdue annual filings (AOC-4, MGT-7, ADT-1) | File all pending forms during the scheme window | Normal fee + 10% of accumulated additional fee |
| Inactive company — no significant business in last 2 FYs | Apply for Dormant Status under Section 455 via Form MSC-1 | 50% of normal filing fee |
| Company wants permanent closure | Apply for Strike-Off via Form STK-2 | 25% of applicable filing fees |
Not covered: Form INC-20A (commencement of business) and Form DPT-3 (return of deposits) are explicitly excluded. Companies already in final ROC strike-off action are not eligible, and a final adjudication order for a specific default is not overridden by CCFS 2026.
Meera and Suresh — same problem, different April
Both run private limited companies incorporated around 2020, both with three financial years of missed filings and similar accumulated fees (~₹2 lakh each). The difference was not which CS they called — it was when.
- Heard about CCFS on 16 April; filed everything in 10 days
- Additional fee paid: ₹20,000 (10% of ~₹2 lakh)
- Total outflow under ₹40,000 incl. fees
- Company active again, DIN clean
- Planned to deal with it in June
- ROC issued an adjudication notice for MGT-7 (2 years)
- Immunity no longer applied to those defaults
- Paid the full penalty for the noticed years
How to actually start — 5 steps for today
- Pull your filing history from MCA21 now. On the V3 portal, check the AOC-4 and MGT-7 status for every financial year since incorporation. Note every “pending” or “not filed” year — that is your exact CCFS 2026 list.
- Calculate your accumulated additional fee. Days since each missed form’s due date × ₹100 per form, both forms added. You pay 10% of this under CCFS 2026 — the larger the figure, the larger the saving.
- Get a compliance review from WeConsult India. Our CS team verifies the exact covered forms, confirms whether any adjudication has been initiated, and handles end-to-end filing. Don’t file outstanding forms without review — the wrong sequence can trigger portal issues.
- File all pending forms before 30 June, not 14 July. Last-minute filings hit congestion, DSC errors and payment failures — every amnesty sees a final-week spike. Filing a month early costs nothing; filing on the last day can cost everything.
- Set recurring reminders for AOC-4 and MGT-7 every year. AOC-4 is due 30 days after the AGM, MGT-7 within 60 days, and the AGM must be held by 30 September. Mark FY 2024-25 now, while the cost of missing is fresh.
Key takeaways
| Compliance point | What to do |
|---|---|
| CCFS 2026 is live 15 April – 15 July 2026 | Start the filing process this week — not in June |
| Additional fee payable = 10% of total accumulated late fees | Calculate your exact figure from the MCA portal before approaching a professional |
| Immunity does not apply if an adjudication order is already passed | Check whether any ROC notice has been issued before assuming immunity |
| No separate form or immunity certificate required | Filing the pending e-forms during the window is sufficient — benefits apply automatically |
But here is the other side…
CCFS 2026 is not blanket immunity from all outstanding defaults. Companies against which final strike-off action has already been initiated, those that have already applied for strike-off, and those that applied for dormant status before 15 April 2026 are not eligible. If your company is already in the ROC’s strike-off pipeline, CCFS 2026 does not reverse it — the right path there is a separate application under Section 252 to the NCLT.
A clean slate is available right now
Compliance backlogs do not resolve themselves — every day of inaction is another ₹200 in additional fees. CCFS 2026 is the clearest signal MCA has sent in years that the government would rather have companies back in the system than penalised out of it. If your company has even one year of missed annual filings, this scheme is worth your attention today — not next month, not after the next quarterly review.
WeConsult India works with companies across Delhi NCR — including businesses in Noida Sector 62, Nehru Place, Greater Noida’s Knowledge Park and the Sector 132 Expressway belt — on compliance-backlog resolution and annual ROC filings. If you are unsure of your filing status or want a professional assessment before approaching the MCA portal, our CS team is available for a consultation.
Stay compliant. Stay protected. — WeConsult India