The CCFS-2026 window has closed. Here is what late ROC filing costs now

Short answer: the Companies Compliance Facilitation Scheme closed on 15 September 2026. From now, an overdue AOC-4 or MGT-7 costs the full ₹100 per day per form in additional fee, uncapped, and the company and its officers are exposed to the adjudicated penalty the scheme used to close off. The immediate priority is the current year: for a 30 September AGM, AOC-4 is due 29 October and MGT-7 on 28 November 2026. If earlier years are also open, the number that matters is not the fee but whether any director is now inside the three-year disqualification window.

What the scheme gave, and what has gone

CCFS-2026 was announced by General Circular 01/2026 dated 24 February 2026 and opened on 15 April. It was meant to run to 15 July, was extended to 31 August by General Circular 03/2026 of 8 July, and then to 15 September by General Circular 04/2026 of 31 August. The second extension changed nothing but the date.

Companies already under a final strike-off notice, with a pending strike-off application, or dissolved by amalgamation were outside the scheme and remain where they were.

What it costs from here: the arithmetic

The additional fee is a portal levy under Section 403 and the Companies (Registration Offices and Fees) Rules. It accrues daily, per form, and it has no ceiling.

Under CCFS that two-year backlog would have cost roughly ₹20,000. That is the concession that has ended.

On top of the fee sits the penalty. It is not automatic; it requires an adjudication order under Section 454. But the scheme's immunity was precisely that filing closed the proceedings before an order could issue, and that protection has gone. The exposure is ₹10,000 plus ₹100 a day, to ₹2 lakh for the company, and the same per-day rate to ₹50,000 for each officer in default, for each of the two sections.

The cost that is not on the challan

The fee is the visible number. Three consequences matter more, and none of them appear on the portal.

1. Director disqualification. Section 164(2)(a) disqualifies every director of a company that has failed to file financial statements or annual returns for any continuous period of three financial years. The disqualification is for five years, it is personal to the director, and it operates in every company where they hold office. Section 167(1) then vacates the office. For a company that has not filed FY 2023-24 or FY 2024-25, the FY 2025-26 filing now due is the one that decides whether its directors cross that line.

2. The IFC exemption. A private company that is inside every financial threshold for the internal financial controls audit exemption still loses it where it has defaulted under Section 137 or Section 92. The consequence is a full controls audit for the year. The test, and a self-check, is in is IFC applicable to your private company.

3. Strike-off. Section 248 lets the Registrar begin removal where a company is not carrying on business. Two years without annual filings is what triggers the notice in practice, and a company struck off with assets, bank accounts or a GST registration attached is a far more expensive problem than the filings would have been.

The FY 2025-26 dates now on the table

Whatever the position on earlier years, the current year runs on its own clock, and that clock starts at the AGM rather than on a fixed date. The full mechanics, including what to have ready, are in AOC-4 and MGT-7: the annual ROC filing after your AGM. The dates:

An AGM held earlier pulls the AOC-4 and MGT-7 dates forward with it. Where the AGM has not been held by 30 September and no extension was obtained from the Registrar, the forms still fall due as though it had been, and the failure to hold it is a separate default.

If earlier years are open: the order of work

1. Establish the last filed year for each form. AOC-4 and MGT-7 do not always stop together. The portal's master data shows the last filed dates.
2. Count the years, not the forms. The Section 164(2) test is three continuous financial years of non-filing of either document. Work out how many years are already inside the window before deciding what to file first.
3. File the oldest year first, and file the current year on time regardless. A late FY 2023-24 filing that lands after the FY 2025-26 due date has not stopped the clock; it has added a form.
4. Check for a Section 454 notice. If an adjudication notice has already issued, the reply window is running and the filing should go in with the reply, not after it.
5. Do not wait for the next scheme. MCA has run amnesties periodically and CCFS-2026 was the most recent. Nothing has been announced to follow it, the fee accrues daily meanwhile, and a disqualification that crystallises in the gap is not undone by a later waiver of fees.

If the company has genuinely stopped, the honest alternative is to close it properly rather than let the fee run. The strike-off route, and what has to be cleared before it, is covered on the company compliance page.

Fees, penalties and dates above are as at 21 September 2026 under the Companies Act 2013 and the Rules, with the scheme circulars cited. MCA extends filing dates and opens schemes by general circular with little notice; check for one before paying a full additional fee on a large backlog, and confirm the current position before filing.