CCFS-2026 closes 15 September: pending ROC filings at 10% of the late fee.

MCA has extended its compliance amnesty a second time, to 15 September 2026. Pending annual filings — including a foreign company's FC-3 and FC-4 — cost 10% of the additional fee.

The Ministry of Corporate Affairs has extended the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) a second time, to 15 September 2026, through General Circular No. 04/2026 dated 31 August 2026, with all other terms of the scheme unchanged. If your Indian company — or your Indian branch or liaison office — has annual filings sitting in arrears, this is the inexpensive window to clear them, and it shuts in under a week.

What the scheme actually does

CCFS-2026 was introduced by General Circular No. 01/2026 dated 24 February 2026. Its central benefit is straightforward: pending annual filings can be made on payment of normal filing fees plus only 10% of the applicable additional fees — a 90% reduction on the late-filing charge that would otherwise apply.

Additional fees under the Companies Act accrue per day and per form, and they compound quietly. For a company two or three years in arrears, the additional fee is routinely the largest line item in the clean-up. Paying a tenth of it is not a rounding error.

Which forms are covered

The scheme covers the annual filing set — MGT-7 and MGT-7A (annual return), the AOC-4 series (financial statements), ADT-1 (auditor appointment), and, importantly for cross-border groups, FC-3 and FC-4, the annual accounts and annual return filed by a foreign company that has established a place of business in India. Corresponding forms under the Companies Act, 1956 are also in scope.

That FC-3 and FC-4 inclusion matters more than it looks. Branch, liaison and project office filings are the ones most often forgotten, because the parent's finance team does not think of the Indian office as a filing entity in its own right. It is one.

Two exits, not just catch-up

CCFS-2026 is not only for companies that intend to keep trading. As reported across professional commentary on the scheme, it offers two other routes:

• Dormant status under Section 455, by filing MSC-1 at half the normal filing fee — sensible for an entity you want to keep alive but idle.
• Strike-off, by filing STK-2 at 25% of the applicable filing fee — for the shell left behind after a restructuring, or a flip that never happened.

Founders sitting on a dormant Indian subsidiary from an abandoned structure should weigh these before 15 September rather than after.

The immunity, and its limits

Immunity from penalty under Section 454(3) is available for Section 92 and Section 137 defaults where filing is made before, or within 30 days of, an adjudication notice. For ADT-1, FC-3, FC-4 and the old-Act forms, immunity applies where filing precedes any prosecution or show-cause notice. No separate immunity application is required.

The limitation is the point. Immunity is tied to not having been caught yet — once adjudication or prosecution has moved past those thresholds, the scheme stops helping.

Why it has moved twice

The first extension, General Circular No. 03/2026 dated 8 July 2026, pushed the original 15 July deadline to 31 August, and was attributed to restoration of MCA21 data centre capacity following a fire on 5 June 2026. The second extension was granted, as reported, in response to stakeholder representations seeking a further window. Two extensions in, a third should not be assumed.

How Advisory Monks Consulting helps

We run the arrears diagnostic — which forms, which years, and what the cost looks like at 10% against the full additional fee — and file inside the window. For foreign parents, we check whether the Indian office's FC-3 and FC-4 history is complete before the deadline forces a rushed answer. Where the right outcome is dormancy or strike-off rather than catch-up filing, we will say so. See our India entry practice and our guide to setting up in India as a foreign company.

General information, not advice; confirm the scheme's terms and dates against the MCA circulars as they stand on the date you act.

This note is general guidance, not tax or legal advice. Positions depend on your specific facts — speak with a partner before acting.