CCFS 2026 Amnesty Scheme

Introduction

For a lot of companies in India, ROC compliance defaults have been a long-term concern. Missing annual filing leads to penalties and over time the piled-up penalty amount increases so much, it becomes impossible to pay and suffice the amount. This is particularly prevalent in the case of startups, small private companies, dormant companies and promoter owned companies where statutory compliances naturally get delayed owing to financial difficulty or operational trouble.

In view of this increasing accumulation of compliance pendency, the Ministry of Corporate Affairs (“MCA”) has launched the Companies Compliance Facilitation Scheme, 2026 (“CCFS-2026”) vide General Circular No. The scheme was introduced 24^th February, 2026 and is valid from 15 April 2026 to 15 July 2026. It permits the companies to file belated ROC forms by way of payment of 10% of the applicable additional fees, thus providing a 90% waiver on penalties for late filing.

Theoretically and practically, the scheme is one of the largest reliefs during compliance issued by MCA since 2020.

The Position Before CCFS-2026

Delayed ROC filings attracted lucrative additional fees before the scheme was introduced, under Section 403 of the Companies Act, 2013. Since July 2018 an amount of ₹100 per day per form has been levied as additional fee for most forms, with no upper limit.

As a result, companies with pending filings coming from multiple financial years would often find themselves saddled with penalties running into lakhs. For instance, delay in submission of Form AOC-4 under Section 137 and Form MGT-7 under Section 92 for a period of three or four years can cause a very huge financial liability for even a small private company.

The consequences were not just additional fees. The following additional risks were also posed to Companies and Directors-

1. Section 454 adjudication,
2. Director disqualification under Section 164(2),
3. Strike off action u/s 248 and
4. Prosecution for continuous non-Compliance.

In many cases, promoters were caught in an impossible bind, too indebted to pay the accumulated penalties and thus unable to close or regularise the company.

What is the CCFS-2026 Scheme?

The CCFS, 2026, is a one-time facility being offered by the Central Government and MCA to the companies to enable them to make good their pending defaults with the ROC at substantially reduced costs. Such companies can now make their overdue filings by paying under the scheme: (together “the regular fees”):

1. The regular filing fees and
2. just 10% of the further fees payable, instead of the prescribed liability and penalty as per the Act and the rules thereunder.

The relief is applicable for certain pending ROC forms such as annual filing forms like:

1. MGT-7 / MGT-7A,
2. AOC-4,
3. ADT-1 and
4. some other specified applications.

The Scheme also provides relaxation of fee for application for dormant status under Section 455 and voluntary strike-off application by a company under form STK-2 under Section 248. But this window of relief stands open only till July 15, 2026.

Why Did MCA Introduce This Scheme & How Does it Helps Companies?

The CCFS-2026 represents a change in approach undertook by MCA. Over the years, government’s attention has been largely on the improving corporate governance and ensuring that records are kept on MCA portal. Simultaneously still, a great number of entities were still non-compliant, whether by reason of financial strain, lack of any specialist help, dispute among management, or inert business operations.

In many cases the late-filing penalties were so extraordinary that companies stopped trying to comply. The fee structure, rather than fixing the compliance environment, created an atmosphere where companies in default would simply stay defaulted eternally. The government seems to have realised that it is more effective to let firms regularise defaults voluntarily than penalise them perpetually and thus kill them off. The scheme is intended to cleanse the corporate records and to bring the firms back to the paths of law.

The largest relief in the scheme is monetary. A company that would have otherwise paid ₹2 lakh or ₹3 lakh as additional filing fees can now regularise the same filings at a fraction of the cost.

The scheme also allows companies to prevent future regulatory problems. Pending ROC filings in particular tend to cause practical problems during:

1. Investment deals,
2. Bank know your customer (KYC),
3. Mergers,
4. Director changes,
5. Shareholder restructuring, and
6. fundraising.

For startups and expanding businesses, outstanding ROC defaults may spell road blocks in investor due diligence. Filing pending forms in the amnesty scheme brings back corporate good name and strengthens legal position of a company.

The scheme will also help if inactive companies are planning to either revive their business or close the entity via strike-off.

Important Compliance Considerations

While there is considerable fee relief under the scheme, the completion of old ROC filings can still be a lot of paperwork. Most companies may also have to reconstruct financial statements, update statutory registers, legalize auditor appointments or complete pending DIN KYC compliances before they can file.

In light of this, entities should not to leave it too late in the scheme. Active and ordinary DSC renewals, signing up for professional certification or getting access to digital signatures may pose some practical challenges in the run-up to the deadline.

Companies should also be aware that the scheme may not automatically revoke penalties already imposed through concluded adjudication proceedings. It would therefore be prudent to conduct a legal audit of the company’s compliance status before filing the documentation.

Conclusion

CCFS-2026 Amnesty Scheme: Seize the opportunity for submitting long pending ROC compliances with minimal expenditure for company and LLP before 15 July 2026.

For companies with years of filing backlogs, the programme can provide a path to restoring legal compliance, cutting exposure to regulatory enforcement and regaining corporate credibility, without the risk of even more punitive fees.

As the timeline is tight, and ROC may possibly have a more stringent approach after closure of the scheme, companies are advised to ideally not wait for the deadline and/or very late stages to begin their scan of the level of their compliance and filing.

Q1. What is the CCFS 2026 Amnesty Scheme for pending ROC forms?

Answer: The CCFS 2026 Amnesty Scheme provides eligible companies an opportunity to file pending ROC forms with substantially reduced additional fees before 15 July 2026. It helps businesses across India regularize corporate compliance and update MCA records efficiently.

Q2. Who can benefit from the CCFS 2026 Amnesty Scheme in India?

Answer: Private limited companies, startups, LLPs, and existing businesses with overdue ROC filings may benefit from the scheme. Companies in Delhi NCR, Mumbai, Bengaluru, Chennai, and other Indian cities can use this window to improve compliance status.

Q3. Why should businesses file pending ROC forms before 15 July 2026?

Answer: Filing before the deadline may significantly reduce financial exposure related to delayed filings. Timely compliance can also help businesses maintain accurate corporate records and avoid future regulatory complications.

Q4. How can Corpzo help with CCFS 2026 Amnesty Scheme compliance?

Answer: Corpzo assists businesses across India in identifying pending ROC forms, preparing documentation, and completing MCA filings within prescribed timelines. Our team helps companies utilize the scheme while maintaining regulatory compliance.

Q5. What happens if a company misses the CCFS 2026 Amnesty Scheme deadline?

Answer: Missing the deadline may result in the loss of available fee reductions and require compliance under standard filing provisions. Businesses should review pending ROC obligations promptly to avoid additional compliance burdens.