The Companies Compliance Facilitation Scheme, 2026 offers a meaningful financial relief — a 90% waiver on accumulated additional fees for pending ROC filings. But relief on paper means nothing if the actual filing process is unclear, delayed, or incorrectly executed.

The CCFS 2026 window runs from 15th April 2026 to 15th July 2026. That is exactly three months. And based on how previous MCA amnesty windows have played out, the final two weeks see a surge in filings — MCA portal congestion, last-minute document scrambles, and preventable errors that cost companies the benefit they waited for.

This blog gives you a structured, step-by-step guide to filing under CCFS 2026 — from identifying what is outstanding, to calculating fees, to submitting forms correctly on the MCA portal, to securing immunity from penalty proceedings.

Before You File: Understand What You Are Dealing With

Filing under CCFS 2026 is not as simple as opening the MCA portal and submitting a form. For most companies with a compliance backlog, it involves reconstructing financial records, preparing audited statements, obtaining board approvals, and managing digital signatures — all before a single form is submitted.

The sooner you start, the better. Here is why: the process of preparing financial statements for multiple prior years — where books may not have been maintained properly or auditors need to be re-engaged — is almost always the most time-consuming part. The MCA portal submission, by comparison, is the final step in a longer preparation chain.

Step 1 — Conduct a Full Compliance Audit

The starting point is knowing exactly what is pending. Log in to the MCA V3 portal at mca.gov.in using your company’s credentials and pull the company’s complete filing history.

For each financial year where filings are outstanding, identify:

• Whether Form AOC-4 (Financial Statements) has been filed
• Whether Form MGT-7 or MGT-7A (Annual Return) has been filed
• Whether Form ADT-1 (Auditor Appointment) is pending
• Any legacy forms from prior years under the Companies Act, 1956

Document every outstanding form with the financial year to which it belongs and the date from which the additional fee began accruing. This gives you a complete picture of your compliance liability — and the basis for calculating savings under CCFS 2026.

Common discovery: Many companies find pending forms they were not aware of when they begin this audit — particularly ADT-1 filings missed during auditor transitions or legacy forms from early years of incorporation. Clearing everything at once is the correct approach.

Step 2 — Calculate Your Fee Liability Under CCFS 2026

Under normal MCA provisions, the additional fee for delayed filing of annual returns and financial statements is ₹100 per day per form, with no upper cap. For a company that has missed filings across two forms (AOC-4 and MGT-7) for three years, the accumulated additional fees can easily reach ₹2 lakh to ₹5 lakh or more.

Under CCFS 2026, you pay only 10% of the total additional fees otherwise payable, in addition to the standard statutory filing fee for each form.

A worked example:

A Private Limited Company has not filed AOC-4 and MGT-7 for three consecutive financial years. Assume the total additional fees across all six pending forms amount to ₹3,00,000.

Item	Normal Cost	Under CCFS 2026
Total additional fees	Rs. 3,00,000/-	Rs. 30,000/- (10% only)
Standard filing fees	Rs. xx (as applicable)	Rs. xx (payable in full)
Total Savings	–	Rs. 2,70,000/-

The MCA portal will automatically calculate the fees payable under the scheme when you initiate the filing during the scheme period. You do not need to manually calculate and enter the reduced amount — the system applies the scheme benefit at the time of payment.

Step 3 — Reconstruct and Prepare Financial Statements

This is typically the most time-intensive step, particularly for companies with multiple years of pending filings.

For each financial year where AOC-4 has not been filed, the company must have audited financial statements — a complete set comprising the Balance Sheet, Profit and Loss Account, Cash Flow Statement (where applicable), Notes to Accounts, and the Auditor’s Report.

If financial statements were not prepared or audited for prior years, this needs to be done now:

• Re-engage or appoint a statutory auditor for the relevant years
• Reconstruct books of accounts where records are incomplete
• Get financial statements signed and audited
• Ensure the auditor generates a UDIN (Unique Document Identification Number) on the current date — the MCA and ICAI have clarified that UDIN can be generated on the date of signing even for prior-year financial statements being filed under the scheme
• Obtain the signed Auditor’s Report and Board’s Report

Practical note: Reconstructing accounts for 3–5 prior years without proper records is a significant task. If your company is in this situation, begin immediately — do not wait until June or July.

Step 4 — Convene a Board Meeting and Pass Required Resolutions

Before filing the financial statements and annual return, the board of directors must formally approve them. This requires:

• Issuing proper notice for a board meeting (minimum seven days, unless shorter notice is consented to by all directors)
• Tabling the audited financial statements at the board meeting
• Passing a resolution approving the financial statements for each pending financial year
• Passing a resolution approving the annual return for each pending year
• Ensuring the meeting minutes are properly recorded and signed

For companies with multiple years of backlog, this may mean holding a board meeting specifically to approve several years of financial statements in sequence. All directors’ DSCs must be active and valid before this stage.

Step 5 — Ensure DSC Validity and DIN Status

Every form filed on the MCA portal requires a valid Digital Signature Certificate (DSC) attached to the director signing the filing. Before proceeding, verify:

• The signing director’s DSC is valid, unexpired, and registered on the MCA V3 portal
• The director’s DIN status is ‘Approved’ — a deactivated DIN due to non-filing of DIR-3 KYC will block form submission
• The DSC is mapped to the correct MCA user ID

If a director’s DIN is deactivated, it must be reactivated by filing DIR-3 KYC-Web and paying the ₹5,000 reactivation fee before proceeding with CCFS 2026 filings. This is a prerequisite — you cannot file AOC-4 or MGT-7 using a deactivated DIN.

Similarly, if the DSC has expired, renewal must be done through a licensed Certifying Authority and re-registered on the MCA portal before filing begins.

Step 6 — File Forms on the MCA V3 Portal

With financial statements prepared, board resolutions passed, and DSCs active, you are ready to file.

Log in to the MCA V3 portal and navigate to the relevant filing section. The sequence of filing matters:

Recommended filing sequence for each financial year:

1. ADT-1 — File the auditor appointment form first, as it establishes the auditor relationship for the financial year being filed
2. AOC-4 — File the financial statements, attaching the audited Balance Sheet, P&L, Cash Flow Statement, Auditor’s Report, and Board’s Report. The form requires the director’s DSC and the auditor’s DSC
3. MGT-7 or MGT-7A — File the Annual Return after AOC-4 is successfully submitted. MGT-7A applies to small companies and OPCs

Repeat this sequence for each financial year with pending filings, working chronologically from the oldest to the most recent.

During the payment step, the MCA portal will automatically apply the CCFS 2026 reduced fee structure — normal filing fee plus 10% of the otherwise applicable additional fee. No separate application or form is required to claim the scheme benefit. The relief is granted automatically upon successful filing and payment during the scheme window.

Step 7 — Verify Acknowledgement and Preserve Records

After each successful submission, the MCA portal generates a Service Request Number (SRN). This SRN is the official acknowledgement of your filing and must be preserved.

Check your registered email for the MCA confirmation. Once filings are processed and approved, the company’s filing status on the MCA portal will reflect the updated compliance position.

Maintain copies of:

• All filed forms with their SRNs
• Payment receipts for fees paid under the scheme
• Audited financial statements for each year filed
• Board resolutions approving the financial statements and annual returns
• DSC certificates and auditor appointment records

These documents form your compliance trail and will be required during any future due diligence, audit, or regulatory inspection.

Step 8 — Confirm Penalty Immunity Status

Once all forms are successfully filed during the scheme period, the immunity from penalty under Sections 92 and 137 of the Companies Act, 2013 is granted automatically — no separate immunity application is required.

The immunity applies if:

• Filings are completed before any adjudication notice is issued, or
• Filings are completed within 30 days of such a notice being issued

If proceedings under Sections 92 or 137 were pending, they are treated as concluded upon successful filing within the scheme period. This effectively removes the threat of prosecution for these specific defaults.

Key Practical Warnings

Do not wait until July. MCA portals experience heavy traffic during the final days of compliance windows. Technical glitches, server downtime, and last-minute form rejections have caused companies to miss previous schemes. Completing your filings by the end of June is the safest approach.

File for all pending years at once. Partial filing — clearing some years but leaving others — leaves the company in a mixed compliance state and may not provide full immunity protection. A complete backlog clearance is always the correct strategy.

The scheme does not excuse AGM defaults. CCFS 2026 condones the delay in filing Annual Returns and Financial Statements. It does not cover defaults in actually holding the Annual General Meeting (AGM). If AGM was not held, that default must be separately compounded with the Regional Director.

Get professional support for multi-year backlogs. Companies with three or more years of pending filings, incomplete books, or disqualified directors face compounded complications that require professional handling — not just form submission.

Need Help Filing Under CCFS 2026?

At Ofin Legal, we manage the end-to-end CCFS 2026 filing process for companies across India — from the initial compliance audit and financial statement reconstruction to board meeting documentation, MCA portal submission, and post-filing confirmation.
We have already begun working with clients whose compliance backlogs span multiple years, and we know exactly how to navigate the practical challenges this involves.

Related Services :

“CCFS 2026: The MCA’s 90% Penalty Waiver Explained”

 “CCFS 2026 Eligibility — Who Qualifies and Who Doesn’t”

“Miss CCFS 2026 and Here’s What It Costs You”

“Annual Compliance Checklist for Private Limited Companies”

“Common Mistakes to Avoid While Filing DIR-3 KYC”

Official Resources:

• MCA V3 Portal — Annual Filing — Ministry of Corporate Affairs
• MCA General Circular No. 01/2026 — CCFS 2026 — Ministry of Corporate Affairs
• Income Tax Portal — UDIN Verification — for auditor UDIN reference