COMMENTS ON INDIAN COMPANY LAW

Tuesday, February 24, 2026

THE SALIENT FEATURES OF THE COMPANIES COMPLIANCE FACILITATION SCHEME, 2026 (CCFS-2026) — THE ONE-TIME COMPLIANCE RELIEF SCHEME NOTIFIED BY THE MINISTRY OF CORPORATE AFFAIRS (MCA) IN INDIA

THE SALIENT FEATURES OF THE COMPANIES COMPLIANCE FACILITATION SCHEME, 2026 (CCFS-2026) — THE ONE-TIME COMPLIANCE RELIEF SCHEME NOTIFIED BY THE MINISTRY OF CORPORATE AFFAIRS (MCA) IN INDIA

FEATURE	DETAILS
SCHEME NAME	Companies Compliance Facilitation Scheme, 2026 (CCFS-2026)
ISSUING AUTHORITY	Ministry of Corporate Affairs (General Circular No. 01/2026)
EFFECTIVE PERIOD	15 April 2026 to 15 July 2026 (3-month window)
OBJECTIVE	One-time opportunity to regularize pending statutory filings at reduced costs and improve compliance levels.
FORMS COVERED	Annual returns & financials under Companies Act, 2013 (e.g., MGT-7, MGT-7A, AOC-4, AOC-4 CFS, AOC-4 XBRL, ADT-1, FC-3, FC-4) and legacy forms under Companies Act, 1956 (Form 20B, 21A, 23AC, 23ACA, 23B, 66, etc.).
ADDITIONAL FEES RELIEF	Only 10 % of the additional fees normally payable for delayed filings (instead of full 100 %
NORMAL FILING FEE	Normal statutory filing fee remains payable as per rules.
IMMUNITY FROM PENALTIES	Conditional immunity from penalties under: • Section 92 (Annual Return) and Section 137 (Financial Statements) if filed before/within 30 days of adjudication notice. • Other e-forms: immunity if no prosecution/notice has been issued prior to filing under scheme.
DORMANT COMPANY OPTION	Companies can apply for Dormant status (Sec 455) by filing e-Form MSC-1 and paying 50 % of normal filing fee.
STRIKE-OFF (CLOSURE) OPTION	Companies may apply for strike-off via e-Form STK-2 and pay only 25 % of the applicable fee (e.g., ₹2,500 instead of ₹10,000).
ELIGIBILITY – WHO CAN AVAIL	All companies with pending eligible filings, subject to conditions.
EXCLUSIONS – INELIGIBLE CASES	• Companies already issued final notice for strike-off under Sec 248 or that have applied for strike-off; • Companies already applied for dormant status before scheme start; • Companies dissolved via amalgamation; • “Vanishing” companies.
POST-SCHEME ENFORCEMENT	After 15 July 2026, Registrars of Companies (RoCs) will initiate action under the Companies Act against remaining defaulters.

ANNEXURE – I

List of Eligible e-Forms Covered under CCFS-2026

A. Forms under the Companies Act, 2013

S.NO	E-FORM	PURPOSE / SECTION
1	MGT-7	Annual Return (Other than OPC & Small Company) – Sec 92
2	MGT-7A	Annual Return (OPC & Small Company)
3	AOC-4	Filing of Financial Statements – Sec 137
4	AOC-4 CFS	Consolidated Financial Statements
5	AOC-4 XBRL	Financial Statements in XBRL format
6	ADT-1	Appointment of Auditor – Sec 139
7	ADT-3	Notice of Auditor Resignation
8	DIR-3 KYC / DIR-3 KYC-WEB	Director KYC Compliance
9	DPT-3	Return of Deposits
10	MSME-1	Half-Yearly Return for MSME payments
11	BEN-2	Return of Significant Beneficial Ownership
12	PAS-3	Return of Allotment
13	INC-22	Notice of Registered Office
14	INC-20A	Declaration for Commencement of Business
15	FC-3	Annual Accounts (Foreign Company)
16	FC-4	Annual Return (Foreign Company)

B. FORMS UNDER THE COMPANIES ACT, 1956 (LEGACY FILINGS)

S.NO	FORM NO	PURPOSE
1	20B	Annual Return
2	21A	Annual Return (Companies without Share Capital)
3	23AC	Balance Sheet
4	23ACA	Profit & Loss Account
5	23AC-XBRL	Financial Statements in XBRL
6	23B	Appointment of Auditor

CATEGORY	ELIGIBILITY STATUS
Companies with pending annual filings	Eligible
Active companies with delayed statutory returns	Eligible
Foreign companies with pending filings	Eligible
Companies intending to become Dormant (Sec 455)	Eligible (via MSC-1)
Companies seeking strike-off (STK-2)	Eligible with concessional fee

2.IMMUNITY FROM PENALTY – CONDITIONS

Section / Default Type	Immunity Condition under CCFS-2026
Sec 92 – Annual Return	Filing before or within 30 days of adjudication notice
Sec 137 – Financial Statements	Filing before or within 30 days of adjudication notice
Other eligible e-Forms	Immunity available if no prosecution initiated prior to filing
Pending adjudication proceedings	Relief available if filing done within prescribed window

1. EXCLUSIONS (NOT ELIGIBLE UNDER CCFS-2026)

Category	Reason for Ineligibility
Companies already struck off	Entity ceased to exist
Companies with final notice under Sec 248	Advanced strike-off stage
Companies dissolved via amalgamation	Legal existence terminated
Companies classified as “Vanishing”	Regulatory risk category
Companies already applied for dormant status before scheme	Not covered under fresh relief

ANNEXURE – III

SPECIAL CONCESSIONAL WINDOWS

Option	Concessional Benefit
Dormant Status (MSC-1)	50% of normal filing fee
Strike-off (STK-2)	25% of prescribed fee
Additional Filing Fees	Only 10% of standard additional fee

YOUR COMPLIANCE PARTNER – R V SECKAR FCS ,LLB 79047 19295

COMPANIES COMPLIANCE FACILITATION SCHEME, 2026 (CCFS-2026)

COMPANIES COMPLIANCE FACILITATION SCHEME, 2026 (CCFS-2026)

Companies Compliance Facilitation Scheme, 2026 (CCFS-2026

The Ministry of Corporate Affairs (MCA) has issued General Circular No. 01/2026 dated 24th February 2026 introducing the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) to provide a one-time opportunity for companies to complete their pending statutory filings in the MCA-21 registry with significantly reduced additional fees. The notification comes in response to various representations from stakeholders seeking relief from financial burden caused due to delayed filings.

Objective of the Scheme

The Scheme aims to:

Improve compliance levels among companies.

Ensure accurate and updated information in the corporate registry.

Support new-age entrepreneurs, MSMEs, producer companies, and OPCs in ease of doing business.

Enable inactive or defunct companies to opt for dormancy or closure at substantially reduced compliance cost.

Key Features of CCFS-2026

Scope & Opportunity Provided

The Scheme offers a one-time condonation of delay for filing various Annual Returns, Financial Statements, and other e-forms under the Companies Act, 2013 and the Companies Act, 1956. Companies may:

Complete pending annual filings by paying 10% of the normal additional fees;

Apply for “Dormant Company” status under section 455 by filing e-form MSC-1 and paying 50% of the normal fee;

Apply for striking-off via e-form STK-2 by paying only 25% of the applicable fee.

Period of Operation

The Scheme will remain in force from 15 April 2026 to 15 July 2026.

Applicable Forms

The Scheme covers multiple e-forms including:

MGT-7, MGT-7A, AOC-4, AOC-4 CFS, AOC-4 XBRL, ADT-1, FC-3, FC-4,

Forms under Companies Act 1956 such as 20B, 23AC, 23ACA, 23AC-XBRL, 23ACA-XBRL, 66, 23B.

Companies Not Eligible

The Scheme does not apply to:

Companies already issued final notice for striking off under Section 248;

Those which have applied for voluntary strike-off;

Companies already granted dormant status;

Companies dissolved via amalgamation;

Vanishing companies.

Fee Structure under the Scheme

As per the circular:

Type of Fee Amount Normal Filing FeeAs prescribed under applicable rules

Additional Fee10% of the normal additional fees prescribed

Immunity from Prosecution & Penalties

The Scheme grants immunity for delayed filings under the following conditions:

Filings are completed before issuance, or within 30 days of issuance, of notice by the adjudicating officer under Sections 92 or 137.

For forms such as ADT-1, FC-3, FC-4, 20B, 21A, 23AC, 23ACA, XBRL forms, 66, and 23B, immunity applies only if filings are made under the Scheme and no prior prosecution or adjudication proceedings have been initiated.

Post-Scheme Action

After the closure of CCFS-2026 on 15 July 2026, Registrars of Companies (RoCs) will initiate necessary regulatory actions against companies that fail to avail benefits of the Scheme and remain non-compliant.

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