CCFS-2026 Has Closed: What ROC Late Filing Costs Now
The Companies Compliance Facilitation Scheme, 2026 closed on 15 September 2026. It ran for just under seven months, was extended twice, and for companies sitting on years of unfiled returns it was the cheapest exit available in a long time.
That window has shut. If your company did not use it, the full late-filing regime is back — and it does not stop at money. This is what it now costs, and what to do about it in the order that matters.
What the scheme actually gave
CCFS-2026 was introduced by MCA General Circular No. 01/2026 dated 24 February 2026, with an original deadline of 15 July 2026. It was extended to 31 August 2026 by General Circular No. 03/2026, and then to 15 September 2026 by General Circular No. 04/2026 dated 31 August 2026. All other terms stayed unchanged through both extensions.
Two reliefs, and the second mattered more than the first:
- Additional fees cut to 10%. Normal filing fees still applied, but the additional (late) fee was charged at a tenth of the usual amount.
- Immunity from penalty and prosecution for the covered defaults, in most cases. The exceptions were where an adjudication order had already been passed, or where the notice period had run out.
The forms covered were the ones companies most commonly fall behind on: MGT-7 and MGT-7A annual returns, the AOC-4 series including XBRL, ADT-1 for auditor appointment, FC-3 and FC-4 for foreign companies, the old Companies Act 1956 equivalents (Forms 20B, 21A, 23AC, 23ACA and 66), MSC-1 for dormant status and STK-2 for strike-off.
Excluded: companies already issued a final strike-off notice, companies that had already filed for strike-off or dormancy, and vanishing companies.
What it costs now
1. Additional fees at ₹100 per day, per form
The flat ₹100-per-day additional fee resumes on every unfiled form, running from the original due date. It does not cap. A company three years behind on both AOC-4 and MGT-7 is carrying six defaults, each accruing independently.
Work out your own exposure on our MCA fee calculator before you decide anything else — the number is usually larger than people expect, and it is the input to every other decision on this page.
2. Adjudication under Section 454
The Registrar can initiate adjudication proceedings. Penalties then follow under Section 92 for the annual return and Section 137 for financial statements — and these attach to the company and to the officers in default, not just to the entity.
This is the part that immunity under CCFS was protecting against. Without it, a filing default stops being an administrative fee and becomes an order with your name on it.
3. Suo-motu strike-off under Section 248
The Registrar can move to strike the company off on its own initiative. For a dormant entity somebody intended to keep alive — a holding company, a name being preserved, a company between projects — this is the outcome that does real damage, because reviving it afterwards means an NCLT petition rather than a filing.
4. Director disqualification under Section 164(2)(a)
Three consecutive financial years of non-filing of annual returns or financial statements disqualifies every director of that company for five years — and the disqualification follows them to every other company they are on the board of.
This is the consequence that is routinely underestimated. A founder with a dormant company they stopped filing for can lose their directorship of the operating business that is paying everybody’s salaries. If that risk is live for you, deal with it before the fees.
Work out which position you are in
Before paying anything, establish the facts. A free company master data search shows the company’s current MCA status, incorporation date and registered office in seconds. A ROC search report will show exactly which forms are outstanding, from when, whether any charge is unsatisfied, and whether the Registrar has already recorded anything against the company.
| Your position | What it means | What to do first |
|---|---|---|
| Behind by one or two filings, no notice received | Fees only, and they are still growing | File now. Every day of delay is priced. |
| Three or more consecutive years unfiled | Section 164(2)(a) disqualification is in play | Check each director’s DIN status before anything else |
| Notice or adjudication already received | Immunity would not have applied even during CCFS | Respond within the notice period — this is time-critical |
| Company genuinely inactive, no intention to revive | Fees accrue indefinitely on a company earning nothing | Consider dormant status or formal closure rather than filing |
If the company is not actually operating
There is no prize for filing years of nil returns on a company nobody intends to use. Two legitimate routes exist, and both are cheaper than carrying the default indefinitely:
- Dormant company status under Section 455 — for a company you want to keep alive but not operate. Reporting obligations reduce substantially.
- Formal closure — a voluntary strike-off on your terms, rather than a suo-motu strike-off on the Registrar’s.
The distinction matters: a voluntary closure is an orderly exit that leaves directors clean. A strike-off initiated by the Registrar, after years of default, is not.
The order to do this in
- Pull the ROC record. Establish what is actually outstanding rather than what you think is. Directors are frequently wrong about which year the filings stopped.
- Check every director’s DIN status. If disqualification has already attached, filing the backlog does not lift it by itself — and it affects their other directorships today.
- Check for notices. Anything with a response window outranks everything else on this list.
- Decide revive or close. Do this before paying fees, not after.
- File oldest first. The oldest default is the one accruing the longest and the one that counts towards the three-year disqualification test.
- Fix the cause. A company that fell three years behind once will do it again without a calendar and someone owning it.
Will there be another scheme?
Nobody can tell you that, and be sceptical of anyone who does. The MCA has run amnesty-style schemes periodically over the years — CFSS in 2020, LLP settlement schemes, and now CCFS-2026 — but each was announced on its own terms, and CCFS-2026 was itself extended twice before closing, which suggests the ministry had already accommodated the demand it intended to.
Planning around a hypothetical future scheme means accruing ₹100 a day per form, and running the Section 164 clock, on the strength of a guess. If the disqualification risk is live, that is not a reasonable bet.
Frequently asked questions
Can I still file under CCFS-2026?
No. The scheme closed on 15 September 2026 and was not extended again. Filings made after that date attract the full additional fee.
Does paying the additional fee clear the penalty exposure?
No. The additional fee is what you pay to file late. It is separate from penalties under Sections 92 and 137, which the Registrar can pursue through adjudication under Section 454. CCFS’s immunity covered the second; paying a fee does not.
My company has been dormant for years. Do I still have to file?
Yes, unless dormant status has been formally obtained under Section 455. An inactive company is not an exempt company — annual filings remain due, and the ₹100 per day runs on a company with no revenue.
I am a director of a defaulting company and also of my operating business. What happens?
If Section 164(2)(a) disqualification attaches through the defaulting company, it applies to you as a director generally, including in the operating company. This is the single most expensive consequence of a neglected shell, and it is why the DIN check comes before the fee calculation.
The company was struck off. Can it be restored?
Restoration is possible but goes through the NCLT under Section 252, with a time limit. It is an order-driven process, not a filing — considerably more expensive and slower than having filed.
Where TAXAJ fits
We handle backlog filings, adjudication responses, dormant status applications and voluntary closures — and we tell clients when closing is cheaper than reviving, because it often is.
If you are not sure where your company stands, the useful first step is a ROC search report and a DIN status check on every director. From there the decision is usually obvious. Ongoing, MCA and ROC compliance and annual filing are what stop this recurring, and for companies without a finance function a virtual CFO arrangement is usually how the calendar actually gets kept.
Related reading: ROC annual filing for a private limited company, forms to be filed with the ROC, and MGT-7 vs MGT-7A.
Schedule a call if you want the position assessed before you commit to filing or closing.
Scheme references: MCA General Circular No. 01/2026 dated 24 February 2026 (CCFS-2026), General Circular No. 03/2026 dated 8 July 2026 (first extension) and General Circular No. 04/2026 dated 31 August 2026 (extension to 15 September 2026). Consequences described are under Sections 92, 137, 164(2)(a), 248, 252 and 454 of the Companies Act, 2013. This is general information and not advice on a specific default — penalty exposure depends on the facts of each company.
