CCFS Scheme Company Compliance in Coimbatore

What is CCFS-2026?

CCFS-2026 is a temporary facilitation scheme under which a company with pending statutory filings can bring its MCA record current by paying the normal filing fee plus ten per cent of the applicable additional fee — effectively a ninety per cent waiver of the accumulated late-filing charge. The additional fee itself continues to arise under section 403 of the Companies Act, 2013; the scheme reduces what the company actually pays.

It exists because the ordinary additional fee on annual filings is ₹100 per day per form with no upper cap. For a company three or four years behind on both the annual return and the financial statements, the arithmetic passes the point where compliance is a rational business decision — the late fee alone can exceed what the business is worth. A facilitation scheme brings the number back to something a founder can actually pay, which is the policy objective.

It is the first broad company amnesty of this kind since the COVID-era schemes of 2020. Such windows are periodic and discretionary, not a standing feature of the law, so the sensible planning assumption is that the ordinary uncapped additional fee is the default and a scheme is the exception.

What is the current status and deadline of CCFS-2026?

Two points of caution. First, the extensions were granted in response to stakeholder representations and, in part, to disruption following the fire at the MCA data centre on 5 June 2026 — they were not a promise of further time, and the last circular did not provide for any. Second, because a scheme deadline is the kind of thing that moves, we confirm the operative position against current MCA circulars before advising on a specific backlog rather than relying on a published date.

If the window has closed by the time you read this, the rest of this guide still matters: the backlog does not go away, and the section below on regularising under normal additional fees is the applicable route.

What relief does the scheme actually give?

Three pathways, and the choice depends on what you intend to do with the company rather than on how large the backlog is.

Note what is not waived in any pathway: the normal filing fee is payable in full on the regularisation route, and the dormant and strike-off concessions apply to the respective application fee, not to the pending annual filings. A company that wants dormant status or strike-off still has to bring its overdue returns current up to the relevant year, and that is where the ten-per-cent concession does its work.

The two exit pathways are covered in their own right in dormant company and winding up of a company, including the eligibility conditions each carries independently of the scheme.

Which forms are covered by CCFS-2026?

The scheme is aimed at annual and related filings, not at every form on the portal. Reported coverage includes the following.

• MGT-7 — annual return
• MGT-7A — abridged annual return for OPCs and small companies
• AOC-4 and its variants, including AOC-4 CFS, AOC-4 XBRL, and the NBFC Ind AS versions
• ADT-1 — intimation of appointment or change of auditor
• FC-3 and FC-4 — annual accounts and annual return of a foreign company
• Legacy forms under the Companies Act, 1956, including 20B, 21A, 23AC, 23ACA, the corresponding XBRL forms, 66, and 23B
• MSC-1 — application for dormant status, at the concessional fee
• STK-2 — application for strike-off, at the concessional fee

The inclusion of 1956 Act forms is genuinely useful, because it brings very old defaults inside the window. What the scheme does not do is cover event-based filings generally — a late INC-22, a late charge filing, or a late allotment return is outside it, and so is director KYC. Confirm each specific form against the circular before assuming the concession applies to it.

Which companies are excluded from the scheme?

1. 1.Companies against which a final notice for striking off under section 248 has already been issued
2. 2.Companies that had already filed an application for voluntary strike-off in STK-2 before the scheme period
3. 3.Companies that had already applied for dormant status in MSC-1 before the scheme’s inception
4. 4.Companies that have been dissolved through a scheme of amalgamation
5. 5.Companies classified as vanishing companies
6. 6.Limited Liability Partnerships, which are governed by the LLP Act, 2008 and fall outside the scheme entirely

Otherwise the scheme is broad: private limited, public limited, One Person Companies, small companies, startups, foreign companies, Nidhi companies, producer companies, and section 8 companies are all reported as eligible.

The first exclusion is the one that creates urgency. A company that has received a final section 248 notice cannot use the scheme, and once a public notice has been issued under section 248(5) it cannot file a strike-off application either. Where a notice has arrived, the stage it has reached needs to be established before deciding anything — and it is worth noting that the third exclusion penalises companies that applied for dormant status early, which is a reason to sequence a dormancy application and a backlog clearance deliberately.

What immunity does the scheme provide?

The scheme is reported to provide conditional immunity from penalty proceedings for default in filing the annual return under section 92 and the financial statements under section 137, operating through the proviso to section 454(3) of the Companies Act, 2013. The protection is a function of timing relative to any adjudication notice.

Read the second row as a hard deadline rather than a cushion. Where a notice has been received, the thirty-day window is the difference between a concluded proceeding and a payable penalty, and it runs from the notice, not from when you get round to reading it. Because the immunity framework depends on the precise wording of the circular and on the stage of any proceeding, we assess it against your actual notices rather than in the abstract — and we do not represent an outcome that depends on an adjudicating officer’s view.

What does a filing backlog cost without a scheme?

This is the baseline the concession is measured against, and it is also the position once the window closes.

• ₹100 per day per form on AOC-4 and on MGT-7 or MGT-7A, for the whole period of delay, with no upper cap
• Both annual forms typically in default together, so the daily rate effectively doubles per year of backlog
• A higher additional fee can apply where there were delays on two or more immediately previous occasions
• Penalty under section 92(5) on the company and on officers in default for the annual return
• Penalty under section 137(3) on the company and on specified officers for the financial statements
• Disqualification of directors under section 164(2)(a) after three continuous financial years of default
• Section 167(1) vacation of office in the director’s other companies as a consequence of that disqualification
• Strike-off action by the Registrar where the company is not carrying on business

The uncapped daily fee is what makes this compound so badly. Two forms in default for three years is over two thousand days of charge across the two, and nothing stops it accruing except filing. The director disqualification is the consequence that outlives the company — it attaches to the person, and curing it means curing the underlying default first, as set out in DIN reactivation.

How does CCFS-2026 compare with earlier schemes?

CFSS-2020 was more generous on the fee but was a pandemic-specific measure and offered no equivalent concession on the dormancy and strike-off routes. CCFS-2026 is less generous on the waiver and more useful on the exits, which reflects a different policy intent: clearing the register of dead entities as much as bringing live ones current.

The pattern to take from the table is that relief windows are periodic, narrow, and not guaranteed to recur. Running a backlog in the expectation of the next scheme is a bet on discretionary policy, and the uncapped daily fee accrues while you wait.

How do you regularise a backlog under the scheme?

1. 1.Pull the company’s complete MCA filing history and identify every pending form and year
2. 2.Check the CIN status for any strike-off tag, and establish whether any section 248 notice has been received and at what stage
3. 3.Confirm the company is not inside any of the excluded categories
4. 4.Calculate the exposure — normal fee plus additional fee per form per year — and then the ten-per-cent figure
5. 5.Confirm every director’s DIN is active and DSC valid, and clear any KYC default first
6. 6.Reconstruct the books for each pending year and complete the statutory audits
7. 7.Have the accounts adopted and the director’s report prepared for each year
8. 8.File in chronological order, starting with the oldest pending year
9. 9.For each year, file AOC-4 before MGT-7 or MGT-7A
10. 10.File ADT-1 and any other covered form for the relevant periods
11. 11.Pay each SRN promptly, and complete all filings within the scheme window
12. 12.Verify on the portal that the filing status is updated for every year

Step five is where most projects stall, not step six. A director whose DIN is deactivated for a missed KYC cannot sign, so the KYC is the first filing in the sequence — see DIR-3 KYC. And the real lead time is the audits: several years of unaudited books cannot be turned into signed financial statements in a week, which is why a scheme deadline announced in February and closing in September still catches companies that started in August.

What documents are needed to clear a backlog?

• Books of account or reconstructed records for every pending financial year
• Bank statements for all accounts, for every pending year
• Audited financial statements and audit reports for each year
• Director’s report and, where applicable, the board’s report for each year
• Minutes of board meetings and of the annual general meeting for each year
• Auditor appointment documents and the eligibility certificate for ADT-1
• Shareholding and director details as at each year end
• Details of loans, deposits, and charges outstanding at each year end — relevant to DPT-3
• Any show-cause or adjudication notice already received, with dates
• Valid Class 3 DSC for the signing director

Reconstructing years of missing records is the honest bulk of this work, and it is worth being realistic about it at the outset. Where bank statements are unobtainable and no books exist, the audit cannot be completed on any basis an auditor will sign, and the pragmatic question becomes whether closure is the better route than regularisation.

What if the scheme window has closed?

The backlog is regularised the ordinary way: file every pending form in chronological order with the full normal fee and the full additional fee under section 403. The additional fee on annual filings is ₹100 per day per form with no cap, so the total is a function of how long the default has run, and it continues to accrue until the filings are actually made.

1. 1.Map the complete backlog and calculate the full exposure per form per year
2. 2.Clear any director KYC default so the forms can be signed
3. 3.Complete the audits for every pending year
4. 4.File in chronological order, AOC-4 before the annual return for each year
5. 5.Assess the section 92(5) and section 137(3) penalty position separately from the additional fee
6. 6.Where a director disqualification has already crystallised, deal with it as a separate workstream
7. 7.Compare the total against the cost of a strike-off or dormancy application before committing

That last step is the decision most founders skip. If the company has no future use, paying several years of uncapped additional fee to bring it current and then closing it is the worst of both worlds. Strike-off still requires overdue filings up to the year business ceased — not up to today — which is often materially less, so establishing and documenting the cessation date properly can change the number substantially.

Were LLPs covered by the scheme?

No. CCFS-2026 applies to companies as defined under the Companies Act, and Limited Liability Partnerships are registered under the LLP Act, 2008 — a separate statute. LLP Forms 3, 4, 8, and 11 are not within the covered list, and no separate LLP amnesty was announced in 2026. The last LLP-specific scheme of this kind was the LLP Settlement Scheme in 2020.

An LLP carrying a backlog therefore pays the full multiplier-based additional fee introduced by the LLP (Second Amendment) Rules, 2022 — including the beyond-360-day slab that adds a continuing daily amount to the maximum multiplier. See LLP annual filing for the ladder, and LLP winding up if closure is the better answer.

Does the scheme remove a director disqualification?

Not directly, but it addresses the cause. Section 164(2)(a) disqualifies a person who is or has been a director of a company that has not filed financial statements or annual returns for three continuous financial years, for five years. The disqualification follows from the default, so curing the default is the precondition for getting it lifted.

A facilitation scheme makes curing the default affordable, which in a multi-year case is the practical obstacle rather than the law. Where the defaulting company has already been struck off, however, it cannot file at all, and restoration through a section 252 application to the NCLT comes first — after which the returns can be filed and the disqualification addressed.

Note also that the earlier CODS-2018 was designed specifically around disqualified directors. CCFS-2026 is framed around the company’s filings rather than the director’s status, so removal from the disqualified list still needs to be pursued with the Registrar after the filings are made.

Should you regularise, go dormant, or close?

The one recommendation that applies in every row is to decide. The single most expensive thing a company can do with a filing backlog is nothing, because the additional fee is uncapped, the penalty exposure builds, and at three years the default reaches past the company to disqualify its directors. A scheme window shortens the arithmetic; it does not change that conclusion.

What is the backlog regularisation checklist?

1. 1.Confirm whether a facilitation scheme is currently open, and its exact closing date
2. 2.Pull the full MCA filing history and list every pending form by year
3. 3.Check the CIN status and whether any section 248 notice has been received, and at what stage
4. 4.Check whether the company falls in any excluded category
5. 5.Check the directors’ status on the ROC disqualified list
6. 6.Clear director KYC defaults so the forms can be signed
7. 7.Calculate the full exposure, and the concessional figure if a scheme applies
8. 8.Compare regularisation against dormancy and strike-off before committing
9. 9.Reconstruct records and complete the audits for each pending year
10. 10.File chronologically, AOC-4 before the annual return for each year
11. 11.Complete every filing inside the scheme window where one applies
12. 12.Deal with any adjudication notice within its own thirty-day window
13. 13.Verify the updated status on the portal and archive the challans and filed copies

Why choose Arjun Filings for CCFS scheme company compliance?

Arjun Filings runs CCFS scheme company compliance as a checklist-first engagement: a qualified CA or CS scopes the work, tells you exactly which documents are needed, and reviews every form before it is signed and submitted. You get a named specialist, a status update at each stage, and a compliance calendar for whatever comes next.

• Specialist support for CCFS scheme company compliance
• Due-date calendar and penalty awareness
• Form review before DSC signing
• Status updates until acknowledgement