The Ministry of Corporate Affairs has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) through General Circular No. 01/2026 dated 24 February 2026, giving companies a practical and timely opportunity to regularize long-pending annual filings at a sharply reduced cost . More importantly, the scheme is not just a technical compliance relaxation; it reflects an understanding of the real struggles faced by MSMEs, private companies, OPCs, and other businesses that often fall behind because of operational pressure, lack of guidance, or financial stress.
Companies Compliance Facilitation Scheme, 2026: A Much-Needed Relief for Defaulting Companies
The Ministry of Corporate Affairs has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) through General Circular No. 01/2026 dated 24 February 2026, giving companies a practical and timely opportunity to regularize long-pending annual filings at a sharply reduced cost . More importantly, the scheme is not just a technical compliance relaxation; it reflects an understanding of the real struggles faced by MSMEs, private companies, OPCs, and other businesses that often fall behind because of operational pressure, lack of guidance, or financial stress.
For many companies, annual filing defaults begin as a small delay and slowly turn into a major compliance burden. Since 1 July 2018, delay in filing annual return and financial statements has attracted an additional fee of Rs. 100 per day without any upper limit, which means even a simple lapse can become financially painful over time.
The MCA appears to have recognized this reality. The circular specifically notes that the number of active companies in India has crossed 20 lakh and that many stakeholders, including MSMEs and private companies, have represented before the Ministry for waiver of additional fees because they could not complete annual compliance in time . In that sense, CCFS-2026 is not merely a legal notification; it is a policy response to the practical compliance difficulties of growing businesses in a formalizing economy.
The core objective of CCFS-2026
The scheme offers a one-time opportunity to companies to either complete their overdue filings, move to dormant status, or apply for strike off, depending on their present business reality . Its stated aim is to improve compliance levels, ensure that the MCA registry shows accurate and updated information, and also help inactive or defunct companies exit or pause operations at a lower cost.
This makes the scheme relevant for three broad categories of entities:
- Companies that are active in business but have delayed annual filings.
- Companies that are not currently operational but want to retain legal existence with minimal compliance through dormant status.
- Companies that have effectively stopped functioning and now want to close in a more economical way.
Effective period of the scheme
The scheme will come into force on 15 April 2026 and will remain available up to 15 July 2026. This means companies have a limited three-month window to review their pending compliance position and take corrective action under the reduced-fee framework.
Businesses should not wait for the last few days. In practical terms, identifying pending forms, collecting financial data, coordinating with auditors, and validating signatories often takes time, especially where defaults relate to multiple financial years.
What relief does the scheme provide?
CCFS-2026 gives companies three practical routes, and each route has a different strategic purpose depending on the status of the company.
| Route | What the company can do | Fee benefit |
| Pending annual filings | File overdue annual return and financial statement related e-forms | Pay normal filing fee plus only 10% of the total additional fees otherwise payable |
| Dormant status | File e-form MSC-1 under section 455 | Pay only one-half of the normal filing fee |
| Strike off | File e-form STK-2 during the scheme period | Pay only 25% of the applicable filing fee |
For active businesses, the first option is the biggest relief because it dramatically reduces the burden of accumulated additional fees. For inactive businesses, the second and third options allow a more sensible compliance decision: either preserve the company at low compliance cost through dormancy or close it with lower filing fees.
The circular defines “relevant e-forms” quite specifically, and this is an important point because the scheme does not apply to every filing form under the Companies Act. The covered forms include annual return and financial statement related forms under the Companies Act, 2013 as well as certain legacy forms under the Companies Act, 1956.
Forms covered under the Companies Act, 2013
- MGT-7
- MGT-7A
- AOC-4
- AOC-4 CFS
- AOC-4 NBFC (Ind AS)
- AOC-4 CFS NBFC (Ind AS)
- AOC-4 XBRL
- ADT-1
- FC-3
- FC-4
Legacy forms covered under the Companies Act, 1956
- Form 20B
- Form 21A
- Form 23AC
- Form 23ACA
- Form 23AC-XBRL
- Form 23ACA-XBRL
- Form 66
- Form 23B
This coverage shows that the scheme has been drafted to address both current compliance defaults and certain older pending filings that may still be unresolved in the MCA system.
The scheme is available to all companies, but with specific exclusions. In simple words, it is meant for defaulting companies that still have a valid path to compliance correction, dormancy, or closure.
However, the following companies are not eligible:
- Companies against which final notice for striking off under section 248 has already been initiated by the Registrar.
- Companies that have already filed an application for striking off their name.
- Companies that had already filed for dormant status under section 455 before the scheme began .
- Companies dissolved pursuant to a scheme of amalgamation.
- Vanishing companies.
This exclusion list is critical. Before advising any client to proceed under CCFS-2026, eligibility should be checked carefully, because a wrong assumption can waste both time and filing effort.
A closer look at the fee benefit
The most talked-about feature of the scheme is the filing relief for pending annual forms. Under CCFS-2026, the company will still pay the normal filing fee as prescribed under the rules, but the additional fee will be restricted to only 10% of the additional fees otherwise payable.
That is a significant relaxation. If a company has old pending annual filings running across several financial years, this reduction can substantially lower the cost of regularization and make compliance practically achievable again.
The benefits for inactive companies are equally useful:
- Filing MSC-1 for dormant status will attract only half of the normal filing fee.
- Filing STK-2 for strike off during the scheme period will require only 25% of the applicable filing fee under the removal of name rules.
This is the part professionals and management teams must read very carefully. The scheme gives relief in terms of delayed filing consequences, but the immunity is not absolute in every case.
For defaults relating to sections 92 and 137, the circular states that proceedings shall be concluded and no penalty shall be leviable if the filings are made under the scheme before issuance of notice by the adjudicating officer or within thirty days of issuance of such notice. This is a major benefit for companies that act quickly before the adjudication process advances too far.
However, where filings are made under the scheme after the 30-day period from the adjudication notice has expired, or where an adjudication order imposing penalty has already been passed, the liability to pay such penalty will remain unchanged. In other words, the scheme can reduce filing fee exposure, but it does not wipe out every penalty situation if the matter has already progressed substantially.
For forms such as ADT-1, FC-3, FC-4 and certain legacy forms, immunity from prospective penal action is available only where the forms are filed under the scheme and no prosecution has already been filed or no adjudication proceedings have already been initiated by issue of show cause notice before such filing. That means timing is everything: early action leads to better protection.
What happens if companies ignore the scheme?
The circular clearly states that after the scheme ends, the concerned Registrars of Companies shall take necessary action under the Act against companies that do not avail the scheme and continue to remain in default. This is not just an optional relaxation notice; it is also a warning that the present window should be used before regular enforcement resumes.
For directors and compliance officers, the message is simple: delay is now far more risky than action. A company that postpones decision-making during a relief period may later face avoidable enforcement, higher outflow, and a more complicated legal position.
Practical guidance for companies
Every company with pending compliance should first assess its true business status and then choose the correct route under the scheme. A practical decision framework could look like this:
- If the company is active and intends to continue operations, complete all pending annual filings under the 10% additional fee benefit.
- If the company is temporarily inactive but may restart in future, evaluate dormant status under section 455.
- If the company is no longer carrying on business and revival is unlikely, consider strike off through STK-2 during the scheme period.
Professionally, this scheme should also be viewed as a good client outreach opportunity for company secretaries, chartered accountants, and legal consultants. Many companies may not even realize that this relief window exists, and timely advisory support can help them save significant cost while restoring legal compliance.
Behind every delayed filing, there is usually a story: a founder trying to save a struggling business, a family-run company with no internal compliance team, a startup that focused on survival over paperwork, or an inactive entity left unattended after plans changed. The law cannot run on emotion alone, but good governance becomes stronger when policy also recognizes ground-level realities.
CCFS-2026 does exactly that. It gives companies a dignified second chance, not by ignoring compliance, but by making compliance possible again.
The Companies Compliance Facilitation Scheme, 2026 is one of the most practical compliance relief measures announced by the MCA in recent times because it combines reduced additional fees, dormancy support, strike-off relief, and limited immunity benefits within a clearly defined window from 15 April 2026 to 15 July 2026. For defaulting companies, the right approach now is not to wait or worry, but to review pending filings immediately and choose the most sensible compliance path before the opportunity closes.
