Companies Compliance Facilitation Scheme, 2026 (CCFS-2026)

Mayur Bhadani
Feb 25
3 min read

A Strategic Compliance Window for Defaulting Companies

The Ministry of Corporate Affairs (MCA) has introduced a one-time compliance window titled Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), effective from 15 April 2026 to 15 July 2026.

This Scheme is not merely a procedural relaxation — it is a structured opportunity for companies to correct long-standing non-compliances relating to Annual Returns and Financial Statements under the Companies Act, 2013.

As a compliance advisor, it is important to understand both the technical structure and the practical implications of this Scheme.

1. Background: Why This Scheme Matters

Under Section 403 of the Companies Act, 2013, delay in filing statutory forms attracts:

₹100 per day additional fee
No upper cap on the additional fee

Additionally, non-filing of:

Annual Return (Section 92)
Financial Statements (Section 137)

may trigger adjudication proceedings and monetary penalties.

Over the years, many private limited companies, OPCs, and small companies accumulated substantial additional fee exposure. CCFS-2026 provides calibrated relief without compromising statutory discipline.

2. Forms Covered Under the Scheme

The Scheme applies to specified “relevant e-forms”, including:

Under Companies Act, 2013:

MGT-7
MGT-7A
AOC-4 (all variants including CFS, XBRL, NBFC formats)
ADT-1
FC-3
FC-4

Certain Forms under Companies Act, 1956:

Form 20B
Form 21A
Form 23AC
Form 23ACA
Form 23AC-XBRL
Form 23ACA-XBRL
Form 66
Form 23B

Only these forms are covered as per the circular.

3. Relief in Additional Fees – Technical Structure

Under CCFS-2026:

Normal filing fees → Payable as per Companies (Registration Offices and Fees) Rules, 2014
Additional fees → Only 10% of the total additional fees otherwise payable

This effectively reduces the additional fee burden by 90%.

Important Clarification:The Scheme does not waive normal filing fees. It reduces only the additional fee component.

4. Immunity from Penalty – Carefully Defined Conditions

A. For Section 92 & Section 137 Defaults

If filings are made under the Scheme:

Before issuance of notice by the Adjudicating Officer; OR
Within 30 days of such notice

Then:

Proceedings shall be concluded
No penalty shall be leviable

However: If adjudication order has already been passed or 30-day period has expired, penalty liability continues as per the Act.

B. For Certain Other Forms

For ADT-1, FC-3, FC-4 and specified 1956 Act forms:

Immunity from prospective penal action applies only if:

The forms are filed under the Scheme; AND
No prosecution has been filed; AND
No adjudication proceedings have been initiated by issue of show cause notice before filing

If proceedings are already initiated, immunity does not nullify such action.

5. Strategic Options for Inactive Companies

CCFS-2026 is not only about filing backlogs. It also provides structured exit or dormancy options:

(A) Dormant Company Status – Section 455

File e-Form MSC-1
Pay only 50% of normal filing fee
Company remains on register with minimal compliance requirements

Suitable for companies not carrying business but wishing to retain corporate identity.

(B) Strike Off – STK-2

File e-Form STK-2
Pay only 25% of applicable filing fees
Legal closure under Companies (Removal of Name of Companies from Register of Companies) Rules, 2016 Suitable where promoters intend complete closure.

6. Who Cannot Avail the Scheme?

The Scheme is not applicable to:

Companies where final notice under Section 248 has already been issued
Companies that have already applied for strike off
Companies that applied for dormant status before commencement of the Scheme
Companies dissolved pursuant to amalgamation
Vanishing companies

7. Post 15 July 2026 – Regulatory Consequences

The circular clearly states that after conclusion of the Scheme:

Registrars of Companies shall take necessary action under the Act against companies who have not availed this Scheme and are in default.

This may include:

Adjudication proceedings
Monetary penalties
Further enforcement action under the Companies Act

Therefore, non-action during this window may increase financial and regulatory exposure.

8. Governance Perspective – Why Directors Should Act

From a corporate governance standpoint, prolonged non-filing impacts:

Director credibility
Due diligence in funding transactions
Bank compliance
Mergers and acquisitions
Credit assessment
Regulatory profiling

Regularising filings during CCFS-2026:

Reduces additional fee exposure
Mitigates litigation risk
Cleans compliance history
Provides structured closure options

9. Practical Advisory Approach

Directors should immediately:

Identify pending financial years
Calculate estimated additional fee exposure
Check status of adjudication or show-cause notices
Decide between:
- Regularisation
- Dormant status
- Strike off

This decision should be taken strategically, not mechanically.

Conclusion

The Companies Compliance Facilitation Scheme, 2026 is a structured, time-bound statutory opportunity — not a blanket amnesty.

It offers:

90% reduction in additional fees
Defined immunity framework
Reduced fee for dormant status
Reduced fee for strike off
A clear compliance reset window

However, benefits are strictly conditional and available only during the Scheme period. For defaulting companies, this window represents a compliance turning point.For responsible directors, it is an opportunity to realign corporate governance with statutory discipline.

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