MCA just extended your compliance deadline to 31 August: what the CCFS-2026 relief scheme actually covers

MCA just extended your compliance deadline to 31 August: what the CCFS-2026 relief scheme actually covers

On 8 July 2026, the Ministry of Corporate Affairs quietly gave thousands of private limited companies a six-week reprieve. General Circular No. 03/2026 pushed the closing date of the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) from 15 July 2026 to 31 August 2026. Most founders will read the headline, exhale, and do nothing — and that is exactly the mistake that turns a 90% fee waiver into a 100% penalty six weeks later.

The extension is not a gift of extra time to relax. It is a narrowing window to clear specific overdue filings at a fraction of the normal additional fee. If you assume it covers every pending form, or that "31 August" resets your regular FY 2025-26 deadlines, you will misread the relief and miss it. Here is what the scheme actually does, what the law requires underneath it, and the exact filings to complete before the window shuts.

What the law actually requires

CCFS-2026 does not change the Companies Act 2013. It is an administrative relief scheme layered on top of the existing filing obligations. The underlying duties are unchanged:

Annual financial statements — Section 137. Every company must file its audited financial statements in Form AOC-4 (or AOC-4 XBRL / AOC-4 CFS as applicable) within 30 days of the Annual General Meeting. Section 137(3) prescribes a penalty of ₹10,000 on the company plus ₹100 per day of continuing default (capped at ₹2,00,000 for the company and ₹50,000 for each officer in default).

Annual return — Section 92. Every company must file its annual return in Form MGT-7, or MGT-7A for small companies and one-person companies, within 60 days of the AGM. Section 92(5) mirrors the AOC-4 penalty structure: ₹10,000 plus ₹100 per day of continuing failure, with the same caps.

Auditor appointment — Section 139. Form ADT-1, intimating the appointment of the statutory auditor, must be filed within 15 days of the AGM at which the auditor is appointed or ratified.

Return of deposits — Rule 16 of the Companies (Acceptance of Deposits) Rules 2014. Form DPT-3, the annual return of deposits and of money not treated as deposits, is ordinarily due by 30 June each year for the preceding financial year.

What CCFS-2026 changes is the cost of filing these forms late — not the obligation to file them. Under the scheme (originally notified by General Circular No. 01/2026 dated 24 February 2026), a company clearing pending AOC-4, MGT-7/MGT-7A and ADT-1 filings pays the normal filing fee plus only 10% of the additional (late) fees that would otherwise apply — an effective waiver of roughly 90% of the penalty for delay.

General Circular No. 03/2026 dated 8 July 2026 extends the availability of that concessional rate to 31 August 2026. The stated reason is operational: capacity enhancement and restoration work at the MCA data centre following a fire incident on 5 June 2026, which disrupted MCA21 services during the peak pre-deadline filing window.

Separately — and this is where founders conflate two different reliefs — the due date for Form DPT-3 for FY 2025-26 was extended to 31 July 2026 without any additional fees, through General Circular No. 02/2026. DPT-3 is not part of the CCFS-2026 10%-fee scheme. It has its own, earlier, hard deadline.

Practical implications — what actually happens if you misread this

The danger of an extension circular is that it invites complacency. Three concrete traps:

Trap 1 — Assuming the scheme covers all forms. CCFS-2026 is limited to overdue annual filings: AOC-4 variants, MGT-7/MGT-7A and ADT-1. It does not cover event-based filings such as PAS-3 (return of allotment), DIR-12 (change in directors), SH-7 (change in capital), CHG-1 (charge creation), or DIR-3 KYC. Those continue to attract full additional fees — ₹100 per day for most event forms, and a flat ₹5,000 reactivation fee plus deactivation of your DIN for a missed DIR-3 KYC. Filing your AOC-4 under the scheme while ignoring a pending DIR-12 leaves you exposed.

Trap 2 — Treating 31 August as a blanket new deadline. The extension applies to the concessional fee window, not to your statutory due dates. If your AGM was held on 30 September 2025, your AOC-4 was due by 30 October 2025 and your MGT-7 by 29 November 2025. Those dates have already passed; the daily additional fee has been accruing. CCFS-2026 lets you settle that accrued liability at 10%. It does not erase the default from your record, and it does not extend the current year's cycle.

Trap 3 — The MCA21 v3 reality. From 1 July 2026, all filings, all master-data searches and all DSC (Digital Signature Certificate) operations are on MCA21 v3 only; the v2 portal has been decommissioned. If your directors' DSCs were last registered on v2, they must be re-associated on v3 before any form can be signed. Founders who wait until late August to start will discover DSC registration failures, PAN-DIN mismatches, and pre-fill errors with no time left to fix them. The v3 system also auto-flags a company with a string of overdue annual filings for closer scrutiny — precisely the profile the scheme is meant to help you exit.

The hard consequence of missing the 31 August window is simple: on 1 September 2026, the additional fee reverts to the full statutory rate under Section 403 and the Companies (Registration Offices and Fees) Rules — up to 12 times the normal fee for filings delayed beyond 180 days. A company that could have regularised for a few thousand rupees in penalty faces tens of thousands, plus the standing risk of prosecution of directors under Sections 92(6) and 137(3) and, in extended default, strike-off proceedings under Section 248.

Step-by-step: what to do before 31 August

• Pull your master data on MCA21 v3 today. Log in, open "View Company/LLP Master Data," and list every annual filing against each financial year. Identify exactly which AOC-4, MGT-7/MGT-7A and ADT-1 filings are outstanding, and for which years.
• File DPT-3 first — its deadline is 31 July, not 31 August. Even a "nil" return is mandatory if your company has any outstanding loans or money received that is not classified as a deposit. Do not let the CCFS extension lull you into missing this earlier, separate deadline.
• Re-register and verify every director's DSC on v3. Confirm the DSC is associated with the correct DIN and is not expired. A Class 3 DSC is mandatory for MCA filings; renew any expiring within the next two months now, because a mid-filing DSC failure can cost you days.
• Complete DIR-3 KYC and any pending event forms in parallel. These sit outside CCFS-2026, so clearing them now prevents a reactivated-but-still-non-compliant company. A deactivated DIN blocks every other filing.
• File the overdue annual forms under the scheme. Complete AOC-4, then MGT-7/MGT-7A, then ADT-1, in that order, paying the normal fee plus 10% additional fee. Keep the challan and SRN for each — this is your evidence of regularisation.
• Do not wait for the last week. With the data-centre restoration still ongoing, MCA21 v3 has seen intermittent slowdowns. Target completion by mid-August to leave a buffer for resubmission if a form is marked for resubmission.

FAQ

Does CCFS-2026 waive the penalty for late DPT-3?
No. DPT-3 for FY 2025-26 has its own relief — no additional fees until 31 July 2026 — under General Circular No. 02/2026. It is not part of the CCFS-2026 10%-fee scheme, and after 31 July the normal additional fee applies.

Which forms qualify for the 10% additional-fee concession?
Overdue annual filings only: AOC-4 (all variants), MGT-7 and MGT-7A, and ADT-1. Event-based forms such as PAS-3, DIR-12, SH-7 and CHG-1, and DIR-3 KYC, are excluded and attract full fees.

Our company was struck off. Can CCFS-2026 help us file?
No. The scheme is for active companies clearing overdue filings. A struck-off company must first seek restoration through an application to the NCLT under Section 252 before it can file anything.

Does filing under the scheme remove the past default from our record?
No. It regularises the filing at a concessional fee and stops further daily penalty from accruing, but the historical delay remains on the MCA record. It does, however, take you off the overdue-filing list that triggers v3 scrutiny and strike-off notices.

For a compliance audit of your company, visit pvtltd.co

The CCFS-2026 extension is a genuine chance to clean your MCA record cheaply — but only if you file the right forms, on the right portal, before 31 August, and handle the DPT-3 and event-based filings that sit outside the scheme. If you are unsure which of your annual filings are overdue or how the v3 migration affects your DSCs, a structured compliance audit will map every pending form and deadline before the window closes. For a compliance audit of your company, visit pvtltd.co.