CCFS 2026 Deadline Missed? What to Do Now
The final Companies Compliance Facilitation Scheme, 2026 deadline was 15 September 2026. If your company still has overdue ROC filings, the priority now is to verify what was actually filed, quantify the remaining defaults and regularise them under the ordinary Companies Act framework—without assuming the expired concession still applies.
Missing CCFS does not mean you should stop filing.
CCFS-2026 closed after 15 September 2026. MCA’s latest verified extension, General Circular No. 04/2026 dated 31 August 2026, moved the deadline only to 15 September. The scheme’s temporary concessions are therefore no longer available unless MCA announces fresh relief. Companies with pending filings should now review their MCA history, calculate the ordinary filing consequences and complete the legally available regularisation route. See CompanyJi’s annual compliance services and compliance calendar.
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CCFS 2026 is closed: the final notified date was 15 September 2026
The Companies Compliance Facilitation Scheme, 2026 was introduced through MCA General Circular No. 01/2026 dated 24 February 2026. Its original closing date of 15 July was extended to 31 August and then, through General Circular No. 04/2026, to 15 September 2026.
Current position: As of 23 September 2026, no later MCA circular extending CCFS beyond 15 September has been verified. A professional-body request, social-media post or portal difficulty does not itself extend a statutory scheme.
What you lose after missing the CCFS 2026 deadline
The underlying compliance obligation does not disappear. What expired is the temporary CCFS treatment that made specified filings and status routes cheaper during the scheme window.
Expired concession
Eligible covered filings could be made during CCFS with the normal fee plus only 10% of the otherwise applicable additional fee, subject to the scheme conditions.
Compliance still remains
Pending financial statements, annual returns and other defaults should still be reviewed and completed where legally permissible under the normal framework.
Do not describe CCFS as a blanket waiver of every penalty or offence. The scheme dealt with specified filings and routes on stated terms. Post-deadline exposure depends on the form, year, company status, notices already issued and the Companies Act provisions involved.
If you tried to file before 15 September, verify whether it actually completed
A draft form, failed upload, unsuccessful payment or portal screenshot is not the same thing as a completed filing. Establish the factual position before deciding the next step.
- Check the SRN and transaction status on MCA.
- Confirm that payment was successful and a challan or acknowledgement exists.
- Confirm the form appears in the company’s filing history where applicable.
- Preserve the submitted form and all attachments.
- Keep portal-error evidence and helpdesk correspondence if a technical failure occurred.
- Do not recreate, alter or backdate evidence to make an unsuccessful attempt appear completed.
A controlled 7-step plan for companies that missed CCFS
The correct response is a compliance reconstruction—not rushed filing of forms whose underlying accounts, approvals or attachments are incomplete.
Pull MCA history
Review master data, filing history, company status and open notices.
Build a year-wise default list
Map every missing financial statement, annual return, auditor filing and event filing.
Close the books
Reconcile bank, GST, TDS, receivables, payables and opening/closing balances.
Restore approvals
Prepare the Board/member records and signatures actually required for the filing set.
Calculate current fees
Use the ordinary filing framework rather than the expired CCFS concession.
Prioritise legal risk
Address ROC notices, status restrictions and blocking defaults before low-risk housekeeping.
File and preserve proof
Store SRNs, challans, forms, attachments and acknowledgements in one compliance file.
Several years of ROC filings pending?
Start with a filing-history review before submitting forms independently.
AOC-4, MGT-7, MGT-7A and other overdue forms after CCFS
Many overdue forms may still be fileable after the scheme, but the company should not assume that every form has the same fee, prerequisites or legal consequence.
| Area | Post-deadline approach | Key control |
|---|---|---|
| Financial statements / AOC-4 | Prepare and file through the ordinary route where legally available. | Financial statements, audit records and approvals must agree. |
| Annual return / MGT-7 or MGT-7A | Regularise the correct year and form under current rules. | Match members, directors, capital and meeting information. |
| Auditor-related filings | Check the actual appointment/tenure facts before filing. | Do not use a filing to paper over an inconsistent auditor record. |
| Event-based forms | Review separately; CCFS was not a universal cure for every company-law default. | Confirm event date, approvals and statutory route. |
For a broader filing framework, see what annual compliance includes.
Do not use the old CCFS fee calculation for a filing made now
The concessional CCFS formula applied during the scheme window. Once the scheme ended, current filings need to be assessed under the ordinary fee provisions and any other applicable consequences.
The temporary additional-fee relief cannot simply be carried forward to a post-15-September filing.
If an ROC notice has already arrived, manage the notice and filing together
A filing backlog and a regulatory notice are related but distinct workstreams. Missing the CCFS deadline makes it more important to control both.
- Record the notice date, response deadline and statutory section.
- Identify the exact financial year, form or event alleged to be in default.
- Check whether filing the pending document is still available and what approvals are required.
- Prepare a factual response supported by filing records rather than generic explanations.
- Track adjudication, strike-off or director-related implications separately where relevant.
Dormant status or strike-off may still be possible—but not on expired CCFS terms
CCFS gave eligible inactive companies temporary concessional routes for dormancy and voluntary strike-off. After the scheme, the ordinary statutory routes remain the reference point.
Keep the company
If the entity has a future purpose but is inactive, assess whether dormant-company status is legally suitable and what current prerequisites apply.
Close the company
If the business is genuinely defunct and eligible, assess voluntary strike-off under Section 248 and the applicable rules. Do not assume CCFS pricing continues.
A company facing a final strike-off notice, unresolved liabilities, litigation or regulatory restrictions needs case-specific review rather than a generic closure checklist.
Build one post-CCFS compliance file before you move on
A strong control against repeated defaults is a clean evidence trail showing what was due, what was filed, what remains open and who owns the next action.
- MCA master data and filing-history snapshot
- Year-wise default and completed-filing register
- Signed financial statements and audit reports
- Board/member approvals and statutory records
- SRNs, challans and payment confirmations
- ROC notices, replies and orders
- DSC validity and authorised-signatory records
- Current compliance calendar with responsible owners
Common mistakes after the CCFS 2026 deadline
The scheme has ended, but avoidable post-deadline mistakes can make the compliance position worse.
Waiting for another extension
Do not let existing defaults grow while assuming MCA will reopen CCFS.
Using the CCFS fee formula
Do not quote or budget expired concessions for filings made after the scheme period.
Filing unreconciled numbers
A fast AOC-4 filing with inconsistent books, tax data or audit records can create a second problem.
Ignoring an ROC notice
A filing does not automatically substitute for a response where the Registrar has separately required one.
Treating drafts as filed
Verify SRN, payment and final status. A saved form is not evidence of completed filing.
Assuming CCFS covered LLPs
LLP defaults require their own LLP-law filing analysis; CCFS-2026 was a company scheme.
CCFS 2026 deadline missed: frequently asked questions
Twenty practical answers for companies dealing with overdue ROC compliance after 15 September 2026.
Is CCFS 2026 still open?
No. The final notified CCFS-2026 deadline was 15 September 2026. From 16 September 2026, the temporary scheme concessions ceased unless MCA issues a fresh relief measure.
What was the final CCFS 2026 last date?
15 September 2026. MCA first extended the original 15 July deadline to 31 August 2026 and then extended it again to 15 September 2026.
Can I still file AOC-4 after missing CCFS 2026?
Where filing is legally available, an overdue AOC-4 can still be completed under the ordinary Companies Act filing framework. The expired CCFS concession should not be assumed to apply.
Can I still file MGT-7 or MGT-7A after the CCFS deadline?
Where the form remains legally fileable, the company should regularise the overdue annual return through the normal filing route and determine the applicable statutory and fee consequences.
Will MCA charge the full additional fee now?
The special CCFS concession is no longer available after the scheme period. The amount payable now depends on the form, delay and ordinary fee rules applicable when the filing is made.
Can a failed upload on 15 September claim CCFS relief?
A failed upload or uncompleted transaction should not automatically be treated as a successful CCFS filing. Preserve portal evidence and verify the SRN, payment and final filing status before taking a position.
What if payment was pending when CCFS closed?
Check the MCA transaction and SRN status. Do not assume a draft or unpaid transaction secured the concession. The actual filing and payment status should be reviewed from portal records.
Should I wait for another CCFS extension?
Do not delay an existing compliance default merely in the hope of another extension. As of 23 September 2026, the latest verified MCA circular extended CCFS only to 15 September 2026.
Can an inactive company still become dormant after CCFS?
Dormant status continues to be governed by the Companies Act and applicable rules, but the special CCFS fee concession has expired. Eligibility and current filing prerequisites should be checked before applying.
Can a company still apply for strike-off after CCFS?
An eligible company may still consider the ordinary strike-off route under Section 248 and the applicable rules. The special CCFS concession for the scheme period should not be assumed to remain available.
Was CCFS 2026 applicable to LLPs?
No. CCFS-2026 was a Companies Act scheme for companies. LLP compliance defaults should be reviewed under the LLP Act and the filing rules applicable to LLP forms.
Is CCFS 2026 the same as CFSS 2020?
No. CCFS-2026 means Companies Compliance Facilitation Scheme, 2026. CFSS commonly refers to the Companies Fresh Start Scheme, 2020.
What should I check first after missing the deadline?
Start with MCA master data and the company filing history. Prepare a year-wise list of missing forms, identify notices or status restrictions, and reconcile the underlying accounts before filing.
Should overdue filings be submitted immediately without review?
Speed matters, but accuracy matters too. Financial statements, annual-return data, auditor information, Board or member approvals and attachments should be internally consistent before submission.
What if the company has received an ROC notice?
Read the notice separately from the filing backlog. Record the response deadline, the section invoked and the specific default alleged, and coordinate the filing and response strategy rather than assuming a late filing alone closes the matter.
Does late filing automatically remove penalties or adjudication risk?
No. Completing a delayed filing can regularise the record, but it does not automatically erase every statutory consequence, notice or adjudication exposure arising from the default.
Can directors be affected by long-standing non-filing?
Persistent non-filing can have consequences beyond portal fees, depending on the nature and duration of the default. Director-related implications should be checked against the company’s actual filing history and current status.
What records should be preserved if we attempted filing before the deadline?
Keep the SRN, challan, payment proof, submitted form, attachments, acknowledgement, portal screenshots or error records and any helpdesk correspondence. These records establish what actually occurred.
What is the best post-CCFS strategy for a company with several years pending?
Use a year-wise compliance reconstruction: close books, reconcile statutory records, identify the correct forms and approvals, prioritise notices and blocking defaults, then file in a controlled sequence.
Can CompanyJi help after the CCFS deadline?
Yes. CompanyJi can assist with filing-history review, annual compliance, overdue ROC filing planning, dormant-status assessment and eligible closure planning based on the company’s current records.
Missed CCFS? Build the correct filing plan now.
Share the company name/CIN, pending financial years, forms you believe are outstanding and any ROC notice received. The first step is to establish the filing position before choosing regularisation, dormancy or closure.
Information updated 23 September 2026. This guide is general information, not a substitute for advice on a company’s specific facts, notices or filing history.