The Ministry of Corporate Affairs launched the Companies Compliance Facilitation Scheme 2026 (CCFS 2026) to give defaulting companies a limited window to file overdue ROC returns at significantly reduced additional fees. For companies sitting on years of pending filings — and directors facing disqualification — this was a critical opportunity.
This guide explains how the scheme worked, what it covered, and the steps to take even if the official window has closed.
What Was the CCFS 2026?
CCFS 2026 was a one-time amnesty-style scheme that allowed companies and LLPs to file overdue annual returns and financial statements without paying the full late fee multiplier that normally applies under the Companies Act, 2013. The scheme ran from 15 April 2026 to 15 July 2026.
It was not the first such scheme — the MCA previously ran similar programmes (CODS 2018, CFSS 2020) — and is unlikely to be the last. Each scheme typically follows a period of accumulated non-compliance.
Which Forms Were Covered?
CCFS 2026 covered the most commonly overdue annual forms:
- AOC-4 — Financial statements (and AOC-4 CFS for consolidated accounts)
- MGT-7 — Annual return for non-small companies
- MGT-7A — Annual return for small companies and OPCs
- ADT-1 — Auditor appointment intimation
- LLP Form 11 — LLP annual return
- LLP Form 8 — LLP statement of accounts and solvency
Event-based forms (DIR-12, CHG-1, SH-7 etc.) were generally not covered under the scheme — these had to be filed with normal late fees.
How the Reduced Fee Structure Worked
Under CCFS 2026, the late fee was capped regardless of the number of years of default. Instead of the standard 12× multiplier for filings more than 180 days late, the scheme offered a flat reduced additional fee per form.
The effective saving was most significant for companies with 3+ years of pending filings — where the normal late fees would have been enormous. For companies with just one or two years of delay, the standard multiplier was often already lower than the scheme's flat fee, so companies had to compare before filing.
Why CCFS Schemes Matter for Directors
The most important reason to use any CCFS window isn't the fee saving — it's director disqualification.
Under Section 164(2) of the Companies Act, 2013, a director becomes disqualified — across every board they sit on — if a company fails to file its annual returns (MGT-7/7A) and financial statements (AOC-4) for 3 consecutive financial years. The disqualification lasts 5 years and applies to all companies the director is associated with, not just the defaulting one.
CCFS schemes allow companies to file the pending returns before (or after) the 3-year threshold and thereby remove the basis for disqualification. See our full guide to Section 164(2) director disqualification for how this works.
What If You Missed the CCFS 2026 Window?
If the July 2026 deadline has passed, the standard MCA late fee structure applies. This means:
- File as soon as possible — the late fee multiplier does not decrease over time, and each passing day may push you into the next bracket
- For companies with 3+ years of non-filing, calculate whether filing now (with full late fees) is still worth it to stop the disqualification clock from reaching the 3-year mark
- Use the MCA fees calculator to work out the exact late fee before you file
The MCA has historically launched a new compliance facilitation scheme every 3–4 years. Watch for government notifications for the next window.
How to File Overdue Returns on MCA V3
- Log in to the MCA V3 portal with company user credentials
- Navigate to the relevant e-form (AOC-4, MGT-7A, etc.)
- Enter the CIN — the form will pre-fill company master data
- Complete the form data for each defaulting year separately (one form per financial year)
- Attach the relevant documents (audited financials, board resolutions)
- Affix the DSC of a current director (note: if DINs are deactivated due to missed DIR-3 KYC, those must be reactivated first)
- Pay the applicable fee (including the late fee multiplier or the CCFS flat fee if within the scheme window)
- Note the SRN for each filing
Reactivating Deactivated DINs Before Filing
A common blocker when trying to clear overdue returns: the directors' DINs have been deactivated because DIR-3 KYC was also missed. Deactivated DINs cannot be used to sign MCA filings.
To reactivate a DIN, the director must file DIR-3 KYC (or DIR-3 KYC Web if details haven't changed) and pay the ₹5,000 reactivation fee per DIN. Do this before attempting to file any overdue annual forms.
Preventing This Situation Going Forward
The most effective way to avoid CCFS dependency is a reliable compliance calendar. Every missed annual filing was once a missed deadline — usually because no one was tracking it, a reminder fell through the cracks, or the MCA portal was uncooperative at crunch time.
Leagully tracks every company's ROC filing deadlines in real time, prepares forms from live MCA data before the deadline, and files directly on MCA V3. Start with the ROC compliance calendar for FY 2025-26 to make sure every current-year deadline is on your radar.