BigCorp Solutions
April 14, 2026
CCFS-2026

CA Kanika Sharma
Founder | BigCorpSolutions
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The Companies Compliance Facilitation Scheme (CCFS), 2026 introduced by the Ministry of Corporate Affairs has emerged as a significant compliance relief measure for defaulting companies. One of the most impactful benefits of the Scheme is the substantial reduction in filing fees, i.e Waiver of 75% Fees, for the companies who are willing to close their companies.
This article focuses on the fee relief available for the companies who got incorporated but not carrying on any business activity and willing do voluntary strike off their business.
Strike Off Comparison – CCFS-2026 vs Normal Regime
| Particulars | Prior to CCFS-2026 (Normal Process) | Under CCFS-2026 Scheme |
|---|---|---|
| Governing Provision | Section 248, Companies Act, 2013 | Section 248 read with CCFS-2026 relaxation scheme |
| Applicability Period | Available anytime | Limited window (15 April – 15 July 2026) |
| Government Filing Fee (STK-2) | ₹10,000 | ₹2,500 (25% of normal fee) |
| Additional/Late Filing Fees (if returns pending) | ₹100 per day per form (no cap in many cases) | Only 10% of total additional fee payable |
| Penalty Exposure for Non-Compliance | Full penalty and adjudication possible | *Conditional immunity from penalty for covered filings |
| Documents Required | Board Resolution, Special Resolution, Indemnity Bond, Affidavit, Statement of Accounts, etc. | Same documents required (no procedural relaxation in documentation) |
| Overall Government Cost Impact | Higher (₹10,000 + full late fees + penalties) | Significantly lower (₹2,500 + 10% additional fees) |
Cost Illustration Example
| Scenario | Normal Regime | Under CCFS-2026 |
|---|---|---|
| STK-2 Filing Fee | ₹10,000 | ₹2,500 |
| Additional Fees (Example: ₹50,000 accumulated on Non-filing of Annual Returns) | ₹50,000 | ₹5,000 (10%) |
| Total Govt. Outflow (Illustrative) | ₹60,000 | ₹7,500 |
Potential savings: ₹52,500 in this illustration
Note: No change in the fee structure of Form MGT-14 for filing the Special Resolution required for the process.
What “Immunity” Covers
If a company files it’s pending statutory returns during the CCFS-2026 window and pays the concessional additional fees (10% of normal additional fees), the following relief is available:
No penalty proceedings for delay in filing covered forms
No adjudication for delay-related defaults
No prosecution for late filing under covered sections
Immunity from additional financial liability beyond scheme payment
In simple terms: once the default is regularised under the scheme, MCA will not initiate or continue penal action for those specific delayed filings.
Why Annual Filing is Necessary
Under the Companies Act, 2013, a private company seeking voluntary strike-off must ensure that all statutory annual filings are completed up to the relevant financial year before submitting the strike-off application.
Section 248(2) permits a company to apply to the Registrar of Companies for removal of its name from the register if it has not commenced business within one year of incorporation or has not carried on business for two immediately preceding financial years.
Further, Rule 4 of the Companies (Removal of Names of Companies from the Register of Companies) Rules, 2016 requires that a company must file all overdue statutory returns before submitting Form STK-2. This includes filing financial statements under Section 137 (Form AOC-4) and the annual return under Section 92 (Form MGT-7/MGT-7A) up to the end of the financial year in which the company ceased its business operations.
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