Introduction:
The Ministry of Corporate Affairs (MCA), through its circular dated 26th February 2026, has introduced the Companies Compliance Facilitation Scheme 2026 (CCFS 2026), for enabling the companies to complete their long pending annual filing at a discounted late fee. We shall try to understand the nuances of this scheme by looking at some Frequently Asked Questions (FAQs).
Q 1. What is meant by the Companies Compliance Facilitation Scheme, 2026?
Ans: The CCFS-2026 refers to one-time opportunity provided by the Ministry of Corporate Affairs to allow companies to complete their pending annual filings or to opt for dormancy or closure with significantly reduced fees
The scheme aims at improving compliance levels and ensure that corporate registry has accurate, up-to-date information
Q 2. What is the purpose of introducing the CCFS 2026?
Ans: As per the circular, the Ministry had received representations stating that it is being difficult for the companies to file the annual filing forms pending since years, due to the exorbitant late fee charged on such delayed filings.
Hence the MCA has introduced this scheme, so that the companies can file the forms and make good their long pending non-compliance without having to pay heavy late fees. The scheme is desirous of facilitating compliances by MSMEs and small companies who may face cash crunch due to such heavy late fee.
Q 3. What is the duration of the CCFS 2026?
Ans: The scheme comes into force on April 15, 2026, and shall remain effective till 15th July 2026. The companies will have a window of 3 months for filing the pending annual filing forms with reduced late fee.
Q 4. What are the eligibility criteria for the companies to take advantage of this CCFS 2026?
Ans: The scheme does not specify any eligibility criteria, instead it prescribes a negative list of companies who cannot take advantage of this scheme. That means, all the companies except those listed billow, can take advantage of this scheme.
The negative list includes the following companies.
- Companies already facing final notice for being “struck off” by the Registrar
- Companies that have already filed for strike-off or dormant status before the scheme began
- Companies already dissolved through amalgamation
- “Vanishing companies”
Q 5. Are Limited Liability Partnerships (LLPs) eligible to take advantage of this scheme?
Ans: No. if we refer to the language of the CCFS 2026, it specifically refers to companies and does not have any mention about LLPs. Also, the list of forms which can be filed under CCFS 2026 does not include the names of LLP forms. Hence it can be said that the scheme does not apply to LLPs.
Q 6. In the year 2019, companies were required to file an e-form INC-22A. if this form was not filed, the company was tagged as active non-compliant in MCA records, and as a result, company was not able to file certain forms like SH-7, PAS-3 etc. If any company has not filed this form INC-22A, then can it take benefit of this scheme?
Ans: Rule 25A of Companies (Incorporation) Rules 2014, provides for list of forms that cannot be filed if company has not filed form INC-22A. This list does not include annual filing forms. That means, even if the company has not filed form INC-22A, it can still file annual filing forms under CCFS 2026.
In fact, proviso to rule 25A states that form INC-22A cannot be filed unless pending annual filing is completed. Also, the form INC-22A requires mentioning of SRN of latest filed forms AOC-4 and MGT-7. Therefore, the company will have to first complete its pending annual filing under CCFS 2026 and only then it can file form INC-22A if not yet filed.
Q 7. Which all forms can be filed with discounted late fee under CCFS 2026?
Ans : Since, the scheme aims at completing pending annual filing, it pre-dominantly allows filing of the annual filing related forms at a discounted late fees. Following is the list of forms which can be filed under this scheme:
- MGT-7 / MGT-7A – Annual Return
- AOC-4 / AOC-4 CFS / AOC-4 (XBRL)/ AOC-4 NBFC (Ind-AS) / AOC-4 CFS NBFC (Ind-AS)
- ADT-1
- FC-3
- FC-4 and
- Their corresponding forms under Companies Act 1956, like Form 20B, 21A, and 23AC) etc.
Other than this, companies desirous of obtaining dormant status or striking off their names from register of companies, can also file forms MSC-1 or STK-2 with discounted fees under this scheme.
Q 8. ow cost effective is filing of forms under this CCFS 2026?
Under this scheme, companies only need to pay the normal filing fee plus 10% of the total additional fees that would otherwise be due for the delay. This is a significant reduction from the standard additional fee of Rs. 100 per day of delay. For example, if form MGT-7 is being filed with a delay of 100 days, then filing fee will be RS. 600 and late fee will be RS. 10,000 (RS. 100*100 days)) that means, fee under normal circumstances will be RS. 10600. But, under this scheme, late fee is reduced to 10% of actual late fee, that is, 10% of 10000 which comes to 1000. Hence amount payable under scheme will be RS. 1,600 instead of RS. 10,600.
Q 9. If any company is desirous of discontinuing its business operations, then does the scheme provide for any option to such companies?
Ans: Inactive companies or such companies who do not wish to continue business, have two cost-effective options:
- they can Apply for “dormant company” status (by filing Form MSC-1 by paying only half of the normal filing fee
- also, they can Apply to be “struck off” by filing Form STK-2 by paying only 25% of the applicable filing fees
However, the scheme provides concession only in case of filing fees. The companies have to follow the complete procedure prescribed in the Companies Act in both these cases, which includes completion of pending annual filing and obtaining necessary approvals.
Q 10. Is there any legal immunity granted to participating companies?
Ans: If filings are made under the scheme, no penalty under section 92 (Annual Return) or section 137 (Financial Statements) for delayed filing of forms, will be leviable Similar Immunity is also granted against prospective penal actions for delayed filings of other forms like ADT-1 or FC-3 etc.
Q 11. Does the scheme prescribe any conditions for receiving this immunity?
Ans: Yes. The scheme clarifies that, For immunity from penal action WRT annual returns and financial statements, the filing must be made either before a notice is issued by an adjudicating officer or within 30 days of such a notice being issued
The scheme further clarifies that; immunity is not granted if a prosecution has already been filed or if adjudication proceedings began before the filing was made under the scheme.
Q 12. Is the company required to undertake any extra filing for availing the above-mentioned immunity?
Ans: The similar amnesty scheme launched by MCA required the companies to file a separate form called CFSS-2020 after completing all pending filings. On filing of this form, a certificate was generated and after showing the same the immunities could be availed.
However, if we refer to CCFS 2026, it does not provide for filing of any extra form or generation/submission of any such certificate. Since not specifically mentioned, it can be concluded that, no additional compliances are required for availing the legal immunities.
Q 13. If the company has not done annual filing for more than 3 years and as a result, the directors of the company have been disqualified under section 164(2) of the Companies Act 2013, in such circumstances, if the company does annual filing under this scheme, then will the disqualification of directors be removed post filing?
Ans: if the company has not filed financial statements or annual returns for more than 3 years, then the directors are disqualified under section 164(2) by act of law.
As per Para 65 and 66 of judgment in the matter of Mukut Pathak & Ors. Vs. Union of India and Anr. Delivered by Delhi High Court, it is clarified that, the disqualification takes place as per conditions specified in the Act and not by order of any authority. Also, this disqualification aims at highlighting the fiduciary duties of directors.
Therefore, the director ones disqualified, will remain disqualified for period of 5 years even if the company completes its annual filing post disqualification.
Additionally, the scheme talks about providing financial relief to the companies by relaxing the late fees. It does not specifically mention any thing about removal of director disqualification.
Q 14. Since year 2019, some documents like statutory audit report or secretarial audit report filed along with financial statements, require mention of UDIN generated by ICAI/ICSI on the date of signing that document. Can the professionals sign the audit reports for previous years along with the UDIN generated as on current date.
Ans: The requirement of mentioning the UDIN became applicable from year 2019. Therefore, in case of the reports bearing dates prior to year 2019, there is no requirement of generating or mentioning UDIN on the documents.
Also, the requirement with respect to UDIN is governed by ICAI/ICSI and not by Ministry of Corporate Affairs. Therefore, the compliance in this regard shall take place as per the guidelines issued by ICAI/ICSI in this regard.
Q 15. As proposed by the scheme, the financial statements and annual returns for earlier years shall be filed by the companies on and after 15th April 2026. However, in between the time to which financial statements relate, and time when they are filed, the applicable legal provisions and formats may have undergone changes. In such circumstances, the companies should prepare the financial statements as per earlier provisions or the current provisions?
Ans: The format for preparation of financial statements shall depend on the date of their approval and signing by the directors. If the financial statements were prepared, approved and signed by the directors during the relevant earlier year but only filing was pending, then they must have been prepared as per formats applicable at that time, which shall be acceptable.
However, if the statements are being prepared and signed today (March 2026), then they will have to be prepared as per currant formats.
For example, format of financial statements prescribed under schedule III of Companies Act 2013 and format of statutory auditor report were amended from FY 2021-22, So if the financial statements for year 2017=18 were prepared and approved in the year 2018 and are being filed in 2026 under CCFS 2026, then old formats are acceptable. But if financial statements for FY 2017-18 were not prepared at that time and are being prepared and approved by board now (March 2026) then the new formats will have to be used.
Q 16. Form filing requirements for small and normal companies are different with respect to applicable e-forms and certification requirements. The definition of small company underwent a change in the month of December 2025. If a company is desirous of filing forms for year 2022-23, and it was not a small company as per the definition at that time, but it is one as per new definition. Then whether it should undertake filing as small company or normal company?
Ans: The MCA V3 portal on the website of Ministry of Corporate Affairs is tuned to except filing as per new definition. Therefore, ones the turnover or paid-up capital of the company is entered, the system will prompt to file e-form MGT-7A and will not ask for certification of professional in form AOC-4. Therefore, it will have to undertake filing as a small company only.
Q 17. The annual filing related e-forms like MGT-7, AOC-4 and ADT-1 etc. have migrated to MCA V3 portal in July 2025. Now if the companies are desirous of filing forms for earlier years under CCFS 2026, then the companies will have to do filing on V3 portal or V2 portal will be enabled for this purpose?
Ans: Since the V2 portal is now disabled and as on date forms can be filed only through V3 portal, the companies will have to file new forms available on V3 portal only.
Q 18. During the period when the scheme is in force, if a company is filing the forms for financial year 2025-26, will it be subject to discounted filing fee?
Ans: The scheme states that it aims at, helping the companies to clear its pending annual filing for earlier years, and provides concession on payment of late fee and not on normal filing fee.
Say if the AGM of the company for FY 2025-26 is held in April 2026, and the due date for filing AOC-4 is in May 2026 and for MGT-7 is in June 2026. Now if the company files both the forms till June 2026, then it will not be subject to late fee and hence will not get any benefit of the scheme.
However, if it does file in July, then late fees will be charged, and it will also be able to avail discount under CCFS 2026.
Q 19. If annual filing by any company is pending for financial year 2024-25, then will it be able to take advantage of this scheme?
Ans: the normal time available for filing annual filing forms for FY 2024-25 has already passed and now if any company is filing the forms for said financial year, then it will have to be done by paying late fees. Since the scheme provides for discount on late fees if forms are filed under the scheme, the company can take advantage of the scheme for filing forms for FY 2024-25.
Q 20. If any company has filed form AOC-4 for any particular year, but has not filed form MGT-7, then will the company be able to take advantage of the scheme for filing only one out of 2 annual filing forms?
Ans: the scheme provides discount on late fees payable on each form. It does not provide any such condition that a particular group of forms has to be filed. Therefore, even if any company is desirous of filing any one out of 2 annual filing forms, it can very well do so.
Q 21. If company is filing the annual filing forms for earlier years, then what would be the date of AGM for approval of financial statements to be mentioned in form?
Ans: if the company has conducted AGM for relevant earlier year and has got the financial statements approved, then such date can be entered. However, if AGM was not conducted, company may now conduct the AGM, get the financial statements approved and then file the same in the form