CCFS-2026 has closed: what pending ROC filings cost now.

MCA's compliance amnesty ended on 15 September 2026 with no third extension. Arrears now carry the full additional fee — and it grows every day they go unfiled.

The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) closed on 15 September 2026. It ran twice past its original date — to 31 August by General Circular No. 03/2026, then to 15 September by General Circular No. 04/2026 dated 31 August 2026 — but no third extension followed. If your Indian company, branch or liaison office still has annual filings in arrears, the cheap route has gone and the ordinary one applies.

What arrears cost now

With the scheme closed, pending annual filings attract normal filing fees plus the full additional fee. The 90% reduction is no longer available. Additional fees accrue per day and per form, so for a company two or three years behind, that line is now the bulk of the cost — and it grows every day the filing is not made. Filing sooner is strictly cheaper than filing later; there is no version of this that improves with waiting.

The two alternative exits still exist, because they are ordinary provisions of the Companies Act rather than creations of the scheme: dormant status under Section 455 via MSC-1, and strike-off via STK-2. What has gone is the discount — the scheme priced them at half and a quarter of the normal fee respectively, and they now cost the normal fee. For a shell left over from an abandoned structure, striking it off is usually still cheaper than carrying arrears forward indefinitely.

The scheme's Section 454(3) immunity has gone with it. Defaults are back to ordinary adjudication.

What the scheme did while it ran

CCFS-2026 was introduced by General Circular No. 01/2026 dated 24 February 2026. Its central benefit was straightforward: pending annual filings could 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 covered 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 was not only for companies that intended to keep trading. As reported across professional commentary on the scheme, it offered 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 still weigh these routes — just at the normal fee now rather than the discounted one.

The immunity, and its limits

While the scheme ran, immunity from penalty under Section 454(3) was available for Section 92 and Section 137 defaults where filing was 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 was the point. Immunity was tied to not having been caught yet — and with the scheme closed, that protection is no longer on the table at all.

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, no third followed — a useful precedent for how much weight to put on an expected extension next time.

How Advisory Monks Consulting helps

We run the arrears diagnostic — which forms, which years, and what the additional fee now totals — and file. Because the fee grows daily from here, the cost of the diagnostic is usually recovered by not waiting. For foreign parents, we check whether the Indian office's FC-3 and FC-4 history is complete, since those are the filings most often missed entirely. 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.