Legal basis: Section 137, 92, 139, 405, 73 of the Companies Act, 2013 read with Rule 25A of the Companies (Incorporation) Rules, 2014 — MCA General Circular No. 01/2026 dated 24 February 2026, extended by General Circular No. 03/2026 dated 8 July 2026. Effective: 15 April 2026 to 31 August 2026. Source: MCA Portal (mca.gov.in). Last reviewed by CA Harun Raaj: August 2026.
What is CCFS-2026 and Why It Matters
The Ministry of Corporate Affairs launched the Companies Compliance Facilitation Scheme 2026 via General Circular No. 01/2026 (24 February 2026) and extended the filing window to 31 August 2026 through General Circular No. 03/2026 (8 July 2026) following MCA data-centre restoration after an infrastructure incident on 5 June 2026.
If your company has overdue annual returns, financial statements, or auditor filings with the Registrar of Companies — this is your final window to file at reduced fees. After 31 August 2026, standard additional fees resume at ₹100 per day per form, with no relief announced. You have three days remaining.
Which ROC Filings Are Covered?
Fee Relief: What You Save by Filing Now
Illustration: A company 730 days overdue on MGT-7 faces ₹73,000 in additional fees under standard rules. Under CCFS-2026: ₹7,300. The 90% savings apply to every overdue form filed within the window.
Key point: Filing overdue ROC returns by 31 August 2026 under CCFS-2026 saves 90% on additional fees for annual filings and interrupts Section 164 director disqualification risk.
Three Consequences of Missing This Deadline
1. Full Additional Fees Resume 1 September 2026
From 1 September 2026, standard daily additional fees of ₹100 per day per form apply with no relief window announced. A three-month delay costs ₹9,000 per form. A one-year delay costs ₹36,500 per form.
2. Director Disqualification Under Section 164(2)(a)
If a company has not filed financial statements or annual returns for three consecutive financial years, every director is automatically disqualified for 5 years from holding any directorship in any company (Section 164(2)(a), Companies Act 2013).
Companies with unfiled returns for FY 2022-23, FY 2023-24, and FY 2024-25 face acute disqualification risk once post-Annual General Meeting (AGM) filing deadlines for FY 2024-25 pass in October–November 2026. Filing even one missing year under CCFS-2026 interrupts the consecutive count and protects directors.
3. ROC Adjudication and Penalty Orders
The ROC has been active in issuing adjudication orders under Section 454 of the Companies Act 2013 for delayed filings. Recent precedent: companies face ₹50,000 company penalty + ₹1,00,000 director penalty for delayed INC-20A filings, plus ongoing daily penalties. Adjudication notices are issued as show-cause orders; responding is mandatory and costly.
Who Is Eligible for CCFS-2026?
- Private Limited companies registered under the Companies Act, 2013
- Public Limited companies (unlisted)
- One Person Companies (OPC)
- Section 8 companies (Charitable/Not-for-Profit)
- No restriction on years of default. Companies 5+ years overdue are eligible.
Not covered:
- Limited Liability Partnerships (LLPs) — separate LLP compliance schemes apply
- Companies under insolvency or liquidation proceedings
- Companies already struck off from the Register
How to File: Step-by-Step Action Plan
Step 1: Access the MCA V3 Portal
Log in to mca.gov.in using your director's registered and associated Digital Signature Certificate (DSC). If DSC association errors occur, email appl.helpdesk@mca.gov.in or call MCA Helpline 0124-4832500 immediately — DSC issues have been common in 2026.
Step 2: Review Filing History
Navigate to My Workspace > Filing History and list all overdue forms by year. Identify all missing AOC-4, MGT-7, ADT-1, MSME-1, DPT-3, INC-22A, and STK-2 filings.
Step 3: Prepare Board-Approved Documents
Obtain board-approved financial statements for each missing year (Section 134(1), Companies Act 2013) and annual return data. Annual returns must reflect all directors, shareholding, and registered office details as of each year-end.
Step 4: File in Chronological Order
File from the oldest financial year forward: AOC-4 first, then MGT-7/MGT-7A, then ADT-1 for each year. Do not skip years.
Step 5: Verify CCFS-2026 Fee Applies
Before payment, confirm the portal displays 10% of normal additional fee for annual filings (or 50%/25% for INC-22A/STK-2). Do not proceed if standard full fees appear.
Step 6: Complete Payment by 31 August 2026
Pay via net banking or NEFT immediately. Payment must be processed and confirmed by 31 August 2026 IST. Do not wait — payment delays risk missing the deadline.
What HRA Handles
Harun Raaj & Associates (HRA) manages CCFS-2026 filings and overdue ROC compliance on a flat-fee basis: verifying eligibility, preparing financial statements and annual returns, filing in chronological order, and confirming fee relief application. Reach out for a audit of your company's filing status and costs.
I'm CA Harun Raaj. If this affects your company's compliance calendar, reach out.
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See Also
Frequently asked questions
Can I file overdue returns for 5+ years under CCFS-2026?
Yes. CCFS-2026 has no restriction on years of default. File in chronological order from the oldest financial year forward, starting with AOC-4, then MGT-7/MGT-7A, then ADT-1 for each missing year. All filings completed by 31 August 2026 receive 10% of normal additional fees.
Does CCFS-2026 cover INC-20A filings?
INC-20A (active company tagging) was not explicitly listed in MCA General Circular 01/2026. Verify eligibility on the MCA V3 Portal before filing. Recent ROC adjudication orders show penalties of ₹50,000 on the company and ₹1,00,000 on the director for delayed INC-20A filings under Section 454, plus ongoing daily penalties.
What happens to my company if I miss the 31 August 2026 deadline?
From 1 September 2026, standard additional fees of ₹100 per day per form resume with no relief announced. ROC may initiate adjudication under Section 454, issue show-cause notices, and proceed with strike-off under Section 248(1)(c). Directors face automatic disqualification under Section 164(2)(a) if the company misses three consecutive years of returns.
Does filing one overdue year stop my director from being disqualified?
Yes. Section 164(2)(a) disqualifies directors only if financial statements or annual returns remain unfiled for three **consecutive** financial years. Filing even one missing year under CCFS-2026 interrupts the consecutive count and protects all directors from the 5-year disqualification.
Are LLPs covered by CCFS-2026?
No. CCFS-2026 covers only companies registered under the Companies Act, 2013. Limited Liability Partnerships (LLPs) are excluded. LLP partners should monitor the MCA website for separate LLP compliance or settlement scheme notifications.
How much will I save by filing overdue AOC-4 and MGT-7 under CCFS-2026?
If your company is 730 days overdue on MGT-7, standard additional fees are ₹100/day × 730 = ₹73,000. Under CCFS-2026, you pay only 10% of that: ₹7,300 — a saving of ₹65,700. The same 90% relief applies to AOC-4, ADT-1, MSME-1, and DPT-3 filings.
What if my DSC is not linked to my company on the MCA portal?
DSC association errors have been common in 2026. Contact MCA immediately: email appl.helpdesk@mca.gov.in or call the MCA Helpline 0124-4832500. Start resolution now — portal errors must be cleared before you can file, and you have only three days until 31 August 2026.
Can I file CCFS-2026 returns if my company is under insolvency or liquidation?
No. CCFS-2026 does not cover companies under insolvency or liquidation proceedings, or companies already struck off from the Register. If your company status is unclear, verify with the ROC or refer to your company's latest MCA V3 Portal dashboard.
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