MetiqThe ₹100-a-day meter on delayed annual filings has no cap, and for companies that fell behind years ago it is often larger than any other number in the conversation. By General Circular No. 01/2026, dated 24 February 2026, the Ministry of Corporate Affairs has opened a one-time window to stop that meter cheaply: the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), in force from 15 April 2026 to 15 July 2026. The Central Government condones the delay — under section 460 read with section 403 of the Companies Act, 2013 — for companies that use the window to file, go dormant, or close.
What changed
For three months, a company in default gets three routes, each priced in the circular itself:
- File and regularise. Complete pending annual filings paying the normal fee for each form plus only 10% of the total additional fees payable for the delay.
- Go dormant. Apply for dormant-company status under section 455 in e-form MSC-1, paying half of the normal fee — the route for inactive companies that want to stay on the register with minimal compliance.
- Strike off. Apply in e-form STK-2 during the scheme, paying 25% of the filing fee — the route for defunct companies that should simply leave the register.
The circular's background is the arithmetic every firm knows: since 1 July 2018, delay in filing annual returns and financial statements has attracted additional fees of ₹100 per day, without any upper limit. With the number of active companies past the 20 lakh mark, the Ministry records that many companies — MSMEs and private companies among them — could not complete annual compliances in time and now carry a growing additional-fee burden.
Who is affected
The scheme covers the relevant e-forms for annual filings under both Acts:
- Companies Act, 2013: MGT-7, MGT-7A, AOC-4, AOC-4 CFS, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), AOC-4 (XBRL), ADT-1, FC-3 and FC-4.
- Companies Act, 1956 (legacy forms): Form 20B, Form 21A, Form 23AC, Form 23ACA, Form 23AC-XBRL, Form 23ACA-XBRL, Form 66 and Form 23B.
Five categories of company cannot use the scheme:
- Companies against which the Registrar has already initiated action by final notice for striking off under section 248;
- Companies that have already applied for strike-off;
- Companies that applied for dormant status before the scheme began;
- Companies dissolved under a scheme of amalgamation;
- Vanishing companies.
Key dates
| Date | What it is |
|---|---|
| 24 February 2026 | General Circular No. 01/2026 issued |
| 15 April 2026 | CCFS-2026 comes into force |
| 15 July 2026 | Last day of the scheme |
| After 15 July 2026 | The circular states the Registrars shall take necessary action under the Act against companies that did not avail the scheme and remain in default |
Impact in numbers
Take one form — say an MGT-7 — filed 200 days late. Outside the scheme, the additional fee is 200 × ₹100 = ₹20,000, on top of the normal fee. Filed under CCFS-2026, the company pays the normal fee in full plus 10% of ₹20,000 = ₹2,000 of additional fee: a saving of ₹18,000 on that one form.
Scale it to the typical defaulter's position — AOC-4 and MGT-7 both 200 days late: ₹40,000 of additional fees outside the scheme becomes ₹4,000 inside it, before normal fees. The longer the default, the more the 10% line matters, because the uncapped meter has been running the whole time.
Immunity: what filing under the scheme does and does not settle
The circular draws this line carefully, and firms should repeat it to clients exactly:
- Sections 92 and 137 (annual return and financial statements). Under the proviso to section 454(3), where filings are made under the scheme before the adjudicating officer's notice is issued, or within 30 days of it, the proceedings are concluded and no penalty is leviable. But where the 30 days after the notice have already expired, or an adjudication order imposing penalty has already been passed, the liability of the company and its officers to pay those penalties does not change — filing under the scheme does not reopen a settled penalty.
- The other forms (ADT-1, FC-3, FC-4 and the legacy 1956-Act forms listed above). Immunity is against prospective penal action for the delayed filings, and only if the forms are filed under the scheme and no prosecution has been filed, and no adjudication proceedings have been initiated by show-cause notice, for that default before the filing.
In short: the scheme cuts fees for everyone who files inside it, and stops penalties only where the penalty process has not already run its course.
What firms should do
- Triage the roster before 15 April 2026. For every company, list the pending relevant e-forms, compute the additional fees each has accrued, and mark which route — file, dormant, strike off — the client actually wants.
- Screen for the five exclusions first. A client inside an exclusion gets no benefit from the window; find that out before promising the 10% figure.
- Check the notice position on sections 92 and 137 defaults. Whether an adjudication notice has issued, and when, decides whether filing also closes the penalty exposure or only the fee.
- Diarise 15 July 2026 as a hard stop, and warn clients who decline the window: the circular states the Registrars shall act against companies that remain in default after the scheme concludes.
FAQ
What exactly does the 10% apply to?
To the additional fees only. For each relevant e-form filed under the scheme, the company pays the normal fee as prescribed under the rules, plus 10% of the additional fees payable for the delay. The normal fee is not discounted.
Which forms can be filed under CCFS-2026?
The annual-filing family: MGT-7, MGT-7A, the AOC-4 variants (including CFS, NBFC (Ind AS) and XBRL), ADT-1, FC-3 and FC-4 under the 2013 Act, and the listed legacy forms — 20B, 21A, 23AC, 23ACA and their XBRL variants, Form 66 and Form 23B — under the 1956 Act.
Our company already received an adjudication notice under section 92. Does the scheme still help?
On fees, yes: the filing still costs 10% of the additional fees. On penalty, it depends on timing — proceedings conclude with no penalty only if the filing is made before the notice or within 30 days of its issuance. If that 30 days has expired, or a penalty order has already been passed, the circular states the penalty liability does not change.
Can a company that wants to close use the scheme instead of regularising?
Yes — closure is one of the scheme's stated purposes. A strike-off application in e-form STK-2 filed during the scheme costs 25% of the applicable filing fee, and an application for dormant status in MSC-1 costs half the normal fee.
What happens to companies that ignore the window?
The circular closes with the Registrars' instruction: at the conclusion of the scheme, they shall take necessary action under the Act against companies that have not availed the scheme and are in default of filing these documents in a timely manner.
Metiq derives every client's AOC-4 and MGT-7 position from its own AGM date and keeps pending annual filings visible across the roster — the triage list CCFS-2026 rewards is the list the system already maintains.
General information only — not professional advice.