MCA Clarifies Key Aspects of Companies Compliance Facilitation Scheme, 2026 Through FAQs

The Ministry of Corporate Affairs (MCA) has issued detailed FAQs on the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), providing much-needed clarity for companies and professionals dealing with pending ROC filings. The FAQs explain eligibility, covered forms, concessional fees, immunity provisions, dormant company options, and strike-off benefits under the scheme.

As per MCA General Circular No. 01/2026 dated 24 February 2026, the scheme is intended to provide a one-time compliance window for defaulting companies to regularize overdue filings at substantially reduced additional fees.

Scheme Period and Applicability

The CCFS-2026 came into force on 15 April 2026 and will remain open until 15 July 2026. Companies can avail the benefits only for filings completed during this period.

The scheme applies to eligible companies registered under the Companies Act, 2013, including private companies, OPCs, startups, and inactive companies with pending annual filings.

However, the FAQs clarify that the following entities are not eligible:

• Companies against which final strike-off action has already been initiated
• Companies that have already filed for strike-off
• Companies that obtained dormant status before commencement of the scheme
• Vanishing companies
• Companies dissolved through amalgamation or merger

Forms Covered Under CCFS-2026

The FAQs confirm that the scheme covers several overdue annual filing forms, including:

• Form MGT-7 and MGT-7A
• Form AOC-4 and related variants
• Form ADT-1
• Forms FC-3 and FC-4
• Legacy forms under the Companies Act, 1956 such as Form 20B, Form 23AC, Form 23ACA, and Form 66

These forms can be filed with significantly reduced additional fees during the scheme period.

Major Relief in Additional Filing Fees

One of the most significant benefits under CCFS-2026 is the waiver of 90% of additional filing fees for eligible overdue forms. Companies are generally required to pay:

• Normal filing fees; plus
• Only 10% of the applicable additional fees

This is a major relief considering that delayed ROC filings currently attract additional fees of ₹100 per day without any upper cap under Section 403 of the Companies Act, 2013.

The FAQs also clarify concessional fees for other actions:

• Dormant status applications under Section 455 can be filed at 50% of normal fees
• Strike-off applications through Form STK-2 can be filed at concessional rates

Immunity From Penalty and Prosecution

The FAQs provide practical clarity on immunity provisions available under the scheme.

Immunity from prosecution or adjudication for delayed filings is available only if:

• The overdue filings are completed within the scheme period; and
• No final notice or adjudication order has already been passed in specified cases

The clarification is particularly important for companies that have already received notices from ROC authorities. The FAQs indicate that immunity may still be available if filings are completed within the permitted timeline and conditions prescribed under the scheme are satisfied.

Consequences of Non-Compliance

The MCA has also clarified that strict action may be initiated after closure of the scheme against companies that continue to remain non-compliant.

Registrars of Companies (ROCs) have been directed to take necessary action against defaulting companies that fail to avail the scheme. This may include adjudication proceedings, penalties, and strike-off actions.

Why Businesses Should Act Now

The FAQs have helped remove several practical doubts surrounding CCFS-2026 and have made the scope of the scheme much clearer for businesses and professionals.

For companies with pending ROC filings, this scheme presents a valuable opportunity to:

• Regularize long-pending compliances
• Reduce financial burden of heavy additional fees
• Avoid future litigation and penalties
• Opt for dormant status or closure where required
• Restore active compliance status with MCA records

Businesses should evaluate their pending compliance position well before the scheme deadline to avoid last-minute filing challenges.

For expert guidance on this topic, contact your tax professional today.