Companies Compliance Facilitation Scheme 2026: MCA's One-Time Amnesty Window for Pending Filings

The Ministry of Corporate Affairs (MCA) has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) through General Circular No. 01/2026 dated February 24, 2026. The scheme came into force on April 15, 2026 and will remain operational until July 15, 2026, providing a three-month compliance window for companies to regularise their pending annual filings at substantially reduced late fees. For the thousands of companies across India that have accumulated years of unfiled annual returns and financial statements, this scheme represents a significant opportunity to clean up their compliance record before the MCA tightens enforcement further.

What CCFS-2026 Offers

The core benefit of CCFS-2026 is a 90 percent reduction in accumulated additional late fees. Companies that file their overdue annual returns and financial statements during the scheme period need to pay only 10 percent of the accumulated additional late fees that would otherwise apply. For companies with multiple years of unfiled returns, the accumulated late fees can run into lakhs of rupees, making this reduction substantial. Beyond the fee reduction, the scheme offers two additional pathways. Inactive companies that wish to remain on the register with minimal compliance obligations can apply for dormant company status under Section 455 of the Companies Act, 2013 by filing e-form MSC-1 at 50 percent of the normal filing fees. Companies that wish to close down can apply for voluntary strike-off by filing e-form STK-2 during the scheme period at 25 percent of the applicable filing fees.

Forms Covered Under the Scheme

The scheme covers the key annual filing forms that most companies are required to file. These include MGT-7 and MGT-7A (annual returns), AOC-4 and AOC-4 CFS (financial statements, including consolidated financial statements), ADT-1 (auditor appointment), FC-3 and FC-4 (annual returns and accounts for foreign companies), and related forms. The scope is focused on annual compliance filings rather than event-based filings such as charge creation, director appointment, or share allotment forms. This means that while the scheme helps companies clear their annual filing backlog, other overdue filings will need to be addressed separately at regular fee rates.

Who Cannot Avail the Scheme

The scheme does not specify positive eligibility criteria. Instead, it prescribes a negative list of companies that cannot take advantage of it. Companies that have been struck off under Section 248 of the Companies Act are excluded, as are companies against which action for striking off is pending. Companies that have been amalgamated or dissolved by order of the National Company Law Tribunal are also excluded. Additionally, companies that have been vanishing companies, meaning companies whose directors have absconded or whose registered office cannot be traced, are not eligible. The negative list approach means that all companies not falling within these excluded categories can avail the scheme, regardless of their size, turnover, or the number of years of pending filings.

How CCFS-2026 Differs from the 2020 Scheme

The MCA had previously run the Companies Fresh Start Scheme, 2020 (CFSS-2020), which served a similar purpose during the COVID-19 pandemic period. CCFS-2026 differs in several important respects. Under CFSS-2020, companies were required to separately file e-form CFSS-2020 to claim immunity from prosecution for delayed filings. CCFS-2026 does not require any separate immunity application form. The benefits are automatically available when the relevant e-forms are filed on the MCA-21 portal during the scheme period and the applicable reduced fees are paid. This simplification reduces the procedural burden on companies and their professionals. The fee structure is also more clearly defined, with the flat 10 percent of accumulated additional late fees providing certainty about the cost of compliance.

Practical Steps for Companies

Companies with pending annual filings should begin preparing immediately. The scheme window closes on July 15, 2026, and the MCA portal can experience congestion during the final weeks of such schemes, based on experience with CFSS-2020. The first step is to identify all pending annual returns and financial statements. Next, the relevant financial statements must be prepared, audited where required, and approved by the board. The forms can then be filed on the MCA-21 portal with the reduced fees. Companies that are genuinely inactive and do not intend to carry on business should consider applying for dormant status or voluntary strike-off during the scheme period to take advantage of the reduced fees for those applications as well. The CCFS-2026 is a time-bound opportunity. Once the window closes, accumulated late fees will revert to their full amounts, and the MCA's ongoing enforcement drive against non-compliant companies will continue without the benefit of any concessional regime.