A S BANKA ADVISORS

The Ministry of Corporate Affairs has opened a 92-day window under the Companies Compliance Facilitation Scheme 2026 (CCFS-2026). From April 15 to July 15, 2026, companies sitting on pending annual filings can settle at 10% of the normal additional fee. For a three-year default, that is the difference between paying Rs 2.19 lakh and Rs 21,900 per company. But the real decision is not about the discount. It is about which of three pathways fits your company.

What This Means for Your Startup

If your company has missed MGT-7, AOC-4, or ADT-1 filings in any year, CCFS-2026 is the cleanest exit you will see this decade. But the scheme is also a forcing function. The MCA has signalled aggressive Section 92 and Section 137 enforcement after July 15, including adjudication penalty orders and strike-off notices under Section 248. Doing nothing is a live risk.

Pathway A: Regularise (for operational companies)

Normal filing fee plus 10% of accumulated additional fees. Covers MGT-7, MGT-7A, AOC-4 (all variants), ADT-1, FC-3, FC-4, and the Companies Act 1956 legacy forms (20B, 21A, 23AC, 23ACA, 66, 23B). Your company remains active, your Director Identification Numbers stay clean, and you unlock bank sanctions, tenders, and due diligence readiness that get blocked by pending filings.

Pathway B: Go Dormant via MSC-1 (for shell-keeping promoters)

50% of the normal MSC-1 fee. Useful if operations have paused but you want to preserve the corporate shell, PAN, carried-forward losses, or a trademark tied to the name. You must still file all pending annual returns up to the dormant date. Many family-held SPVs and IP-holding companies fit here.

Pathway C: Voluntary Strike-Off via STK-2 (for permanent exit)

25% of the normal STK-2 fee. Right answer for non-operational companies with no revival plan. Again, you must clear pending annual returns up to the strike-off date before filing STK-2. Evaluate tax carry-forwards and bank account implications before committing.

The Three Decisions That Cost Most Companies the Benefit

1. Waiting till late June or July. The MCA-21 V3 portal will congest in the final two weeks. Service Request Numbers stall, resubmissions get stuck, and some companies will miss July 15 by no fault of their own. Target mid-June for filing completion.

2. DSC failures for overseas directors. NRI founders and international board members with expired or unregistered Digital Signatures are the single largest operational risk. Audit every signing director’s DSC status by April 30. Renewal via eMudhra or NSDL can take a week.

3. Losing the bigger prize (prosecution immunity). The 10% concession is the visible number. The quiet benefit is immunity from Section 92 and 137 prosecution if you file before an Adjudicating Officer notice lands or within 30 days of receiving one. Once that 30-day window closes, the fee concession still applies but personal director liability does not go away.

A Decision Framework Before You File

Start with three questions:

1. Does the company have a live commercial case (customers, bank accounts, employees, contracts)? If yes, Pathway A.
2. Does the company hold IP, loss carry-forwards, or a name you want to protect? If yes, Pathway B.
3. Is the company dead with no revival plan and no residual value? If yes, Pathway C.

Then build your filing matrix: one row per pending form, per financial year. Oldest year first is non-negotiable on V3. Verify DSCs, prepare audited financials and board resolutions, estimate fees, and block calendar time in May or early June.

What Is Not Covered

CCFS-2026 does not cover DPT-3, BEN-2, DIR-3 KYC, CHG-1, or event-based forms. Those continue at normal rates. LLPs are also excluded. Companies with a final strike-off notice, Vanishing Companies on MCA watch lists, and companies with finalised penalty adjudication orders cannot use the scheme.

Download the Step-by-Step V3 Portal Walkthrough

Our 9-slide carousel covers the fee math, all covered forms, the six-step MCA V3 filing playbook, the immunity matrix, and the pre-filing checklist broken down by owner. Download the full CCFS-2026 Practical Filing Guide PDF.

When Expert Help Saves You More Than the Fees

If you are sitting on 3+ years of pending filings or operating across multiple group companies, a sequencing mistake can cost you more than the entire fee saving. Choosing the wrong pathway or filing out of order triggers portal rejections that push you past July 15.

Need help mapping the right pathway for your company? Get Expert Guidance from A S Banka Advisors Private Limited. Book a quick call: https://calendly.com/asbanka-info/30min.