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MCA Update — April 2026

MCA’s CCFS 2026 Scheme Is Live: Get 90% Waiver on ROC Late Fees Before July 15 — Here’s What Every Startup Must Know

A one-time amnesty window to clear all pending ROC filings at a fraction of the usual cost. Act before it closes on July 15, 2026.

📅 April 23, 2026
⏳ Closes: July 15, 2026
💸 90% Fee Waiver
🏢 Bhavya Sharma & Associates

If your startup has missed ROC filings or has pending annual returns piling up, the Ministry of Corporate Affairs has just handed you a rare opportunity to fix everything — legally, cleanly, and at a fraction of the usual cost. But the window is open only until July 15, 2026. Here’s everything you need to know about the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026).

What Is the MCA CCFS 2026 Scheme?

The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) is a one-time amnesty programme introduced by the Ministry of Corporate Affairs vide General Circular No. 01/2026 dated February 24, 2026. It allows companies that have missed annual compliance deadlines to clear pending ROC filings by paying only 10% of the additional (late) fees that would otherwise be due — effectively giving you a 90% waiver on penalty fees.

Think of it as the government pressing the “reset” button on ROC non-compliance — and giving businesses a limited-time window to get back in good standing without being crushed by accumulated penalties.

⏳ Key Dates — Mark These Now

🟢

Scheme OpensApril 15, 2026
🔴

Scheme ClosesJuly 15, 2026
⚠️

After July 15Strict ROC Action Begins
📓

Circular RefMCA No. 01/2026
⚠️ Don’t Wait Until June
You have 3 months — but gathering audited financials, board resolutions, and filing forms through a CS professional takes time. Most founders who wait until June end up scrambling. Start now.

Why Should Every Startup Founder Care?

A large number of Indian startups — especially early-stage ones — miss ROC filings in their first few years. Founders are busy building the product, managing investors, and hiring teams. Annual compliance slips.

The problem? Those missed filings don’t disappear. They accumulate penalties. And when you go for due diligence — Series A, a bank loan, a government contract — those gaps come back to haunt you. Investors will spot them. Acquirers will flag them. Fixing them retroactively gets expensive.

This scheme changes the equation. Instead of paying full accumulated penalties — which can run into lakhs across years — you can clear everything for just 10% of those additional fees.

✅ Who Is Eligible for CCFS 2026?

  • Private Limited Companies (most startups fall here)
  • One Person Companies (OPCs)
  • Small Companies and MSMEs
  • Public Limited Companies
  • Foreign Companies registered in India
  • NBFCs and other regulated companies with pending MCA filings

💰 What Exactly Is the Fee Structure?

100%Normal Fee (Paid in Full)
10%Of Late Fees Paid
90%Waiver You Get
✅ Real-World Example
If your company missed 3 years of annual filings and the accumulated additional fee would have been ₹5 lakh, under CCFS 2026 you pay only ₹50,000 in additional fees — plus normal statutory charges. That’s a massive saving.

📋 Which Forms Are Covered?

Annual Return Forms

Form Purpose Who Must File
MGT-7 Annual Return All companies (except OPCs & small cos)
MGT-7A Annual Return (simplified) OPCs & Small Companies

Financial Statement Forms

Form Purpose
AOC-4 Filing of Financial Statements
AOC-4 CFS Consolidated Financial Statements
AOC-4 (XBRL) For companies required to file in XBRL format
AOC-4 NBFC (Ind AS) For NBFCs following Indian Accounting Standards

Other Key Forms

Form Purpose
ADT-1 Appointment of Auditor
FC-3 & FC-4 For foreign companies with Indian registrations
Form 66 Compliance Certificate (certain companies)

🛡️ Immunity From Penalties: How It Works

File before a notice is issued → Full immunity. No penalty levied. Proceedings concluded.

File within 30 days of receiving a notice → Proceedings still concluded with immunity.

More than 30 days after notice / order passed → Reduced fee benefit applies, but existing penalty liabilities remain.

💡 Key Takeaway
The earlier you act, the more protection you get. Don’t wait for a notice to trigger action.

⚠️ What Happens If You Miss July 15?

  • ROC notices and penalty orders — directors can be personally liable
  • Director Disqualification under Section 164(2) — barred from any directorship for 5 years
  • Compounding of offences — costly and time-consuming legal process
  • Striking off the company from the register
  • Major investor red flag — no VC/PE will proceed with DD if MCA filings are incomplete
  • Bank credit blocked — no lender extends credit to a company with broken compliance

🎁 Bonus Relief Under CCFS 2026

Dormant Status Application
50% Discount

For inactive companies that want to legally declare dormancy under the Companies Act and avoid future annual filing obligations.

Striking Off Defunct Companies
75% Fee Reduction

For founders wanting to formally wind down an old, inactive company without paying heavy accumulated penalties. Now’s the time.

📅 Standard ROC Compliance Calendar

Form Purpose Deadline
AOC-4 Financial Statements Within 30 days of AGM
MGT-7 / MGT-7A Annual Return Within 60 days of AGM
ADT-1 Auditor Appointment Within 15 days of AGM
DIR-3 KYC Director KYC September 30 each year
MGT-14 Board/Shareholder Resolutions Within 30 days of resolution

🚀 How to File Under CCFS 2026

1
Identify all pending forms

Check your company’s filing history on the MCA21 portal (mca.gov.in) using your company’s CIN.

2
Gather required documents

Audited financial statements, board resolutions, annual return data, Director DIN and DSC details.

3
Engage a qualified Company Secretary

Filing under CCFS 2026 involves multiple e-forms. A practicing CS professional ensures accuracy and avoids rejections.

4
File all pending forms on MCA21

Pay the statutory fee + just 10% of additional fees at the time of filing each form.

5
Download acknowledgements & SRNs

Save all filing receipts and SRN numbers safely for future reference and investor due diligence.

❌ Common Mistakes Founders Make

Assuming a dormant company doesn’t need to file — Wrong. Every registered company must file annually unless formally declared dormant.

Waiting for the CA to remind them — Your CA handles taxes. Your CS handles ROC filings. Two different mandates, two different professionals.

Not knowing their AGM date — The AGM triggers most ROC deadlines. If you don’t know yours, find out now.

Missing DIR-3 KYC — Director disqualification is real and happens more often than founders think.

Thinking penalties are small — Under the Companies Act, penalties compound at ₹200/day per form. Across years, this adds up fast.

❓ Frequently Asked Questions

Can a startup that missed 5 years of filings use CCFS 2026?
Yes. The scheme covers all outstanding pending filings regardless of how many years have been missed, as long as the forms fall within the covered list and you file before July 15, 2026.

Do I need a Company Secretary to file under CCFS 2026?
Strongly recommended. The forms require digital signatures from directors and a practicing CS or CA. Errors can lead to rejected filings and lost time — especially in a time-bound scheme.

Does CCFS 2026 apply to LLPs?
No. CCFS 2026 applies specifically to companies registered under the Companies Act, 2013 and 1956. LLPs are governed separately and this scheme does not cover LLP annual filings.

We’ve already received a penalty notice. Can we still benefit?
Yes, if you file within 30 days of receiving the notice, you still get immunity under CCFS 2026. If more than 30 days have passed or an order has been passed, the reduced fee benefit still applies — but existing penalty liabilities remain.

Can we use CCFS 2026 to close a defunct company?
Yes. The scheme offers a 75% fee reduction on striking-off applications. If you have an inactive company you’ve been delaying closing because of penalties, CCFS 2026 makes now the right time to act.

Don’t Let This Window Close on You.

At Bhavya Sharma and Associates, our Company Secretaries are already helping founders clear pending ROC filings under CCFS 2026 — from identifying all pending forms to filing them correctly on the MCA portal. Let us handle it so you can focus on building.

Sources: MCA General Circular No. 01/2026 · TaxGuru · IndiaFilings · StartFilings · Finodha | Data as of April 2026

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