AOC-4, MGT-7, ADT-1 Filing 2026: CCFS Amnesty Has Now Closed

The Companies Compliance Facilitation Scheme, 2026 shut on 15 September 2026. No third extension followed, even after the Institute of Company Secretaries of India formally asked the Ministry of Corporate Affairs to push the window to 30 September. If your company is sitting on an unfiled AOC-4, MGT-7 or ADT-1 from an earlier year, the 90% discount on additional fees is gone. The ₹100-a-day meter is running again, and it has been running since 16 September.

That single fact changes how this AGM season should be planned, because most guides written even a week ago still describe the amnesty as open. This piece covers both threads: the annual filing sequence every company faces after its 2026 AGM, and where things stand now that the older backlog window has closed.

The filing chain your AGM date starts

A company whose financial year ended 31 March 2026 must hold its AGM by 30 September 2026 under Section 96. Three filings follow, and each clock starts on the actual date the meeting happens, not on 30 September and not on the financial year-end.

Hold the AGM early and every downstream date moves earlier with it. There is a dependency that catches people off guard: MGT-7 pulls its financial figures from the AOC-4 record once it has cleared MCA processing. Filing AOC-4 on day 29 leaves no room if it needs resubmission, and the 60-day MGT-7 clock keeps running regardless.

The ADT-1 fee myth almost everyone repeats

Several filing guides describe ADT-1 as carrying the same flat ₹100-a-day fee as AOC-4 and MGT-7. It doesn't, and the distinction sits in the rule text itself. The Companies (Registration Offices and Fees) Amendment Rules, 2022 carved out forms filed under Sections 92 and 137 of the Companies Act, which is where AOC-4 and MGT-7 sit, into their own flat additional-fee track. ADT-1 falls under Section 139, and Section 139 stayed inside the general multiplier table.

Under that table, a delay of up to 15 days on ADT-1 costs one time the normal fee. Beyond 15 and up to 30 days it jumps to two times, then four times up to 60 days, six times up to 90 days, ten times up to 180 days, and twelve times beyond that. Miss ADT-1 by four months and you are paying ten times the base fee, not a flat day count. Treating it like AOC-4 badly understates the real number for anyone who has let auditor-appointment filings slide for months.

What a delay actually costs, in rupees

The normal fee for AOC-4 and MGT-7 depends on authorised share capital.

The ₹100-a-day additional fee sits on top of that normal fee, and it applies per form. For a company in the middle capital slab, six months of delay on AOC-4 and MGT-7 together adds roughly ₹36,700 to the two normal fees combined. A full year crosses ₹73,000. Add a similarly stale ADT-1 and the multiplier table can push its own additional fee past ten times the ₹300 to ₹600 base once the delay clears 90 days, a separate cost on top of the other two forms.

What CCFS-2026 covered, and why the closure matters now

CCFS-2026 let companies clear pending AOC-4, AOC-4 XBRL, MGT-7, MGT-7A, ADT-1 and several older company-law forms by paying the normal fee plus only 10% of the accrued additional fee, with immunity from prosecution for the filing default itself. The scheme opened on 15 April 2026, was meant to close on 15 July, and was pushed twice: first to 31 August through General Circular No. 03/2026, then to 15 September through General Circular No. 04/2026 dated 31 August 2026.

ICSI asked for a further extension to 30 September, citing MCA-21 V3 portal difficulties and the DIN reactivation and DSC renewal work that a backlog filing often needs first. The Ministry has not acted on that request. As things stand today, 15 September remains the final closing date, and no company can still use the concession for a pre-existing backlog.

Based on MCA General Circular No. 04/2026 dated 31 August 2026, extending CCFS-2026 to 15 September 2026.

Life after 15 September: the default regime is back

Once the scheme lapses, a company with an unfiled backlog faces the ordinary consequences again, and they stack. The ₹100-a-day fee resumes on AOC-4 and MGT-7 without the 90% reduction. The Registrar can open adjudication proceedings under Sections 92 and 137 for the underlying default, separate from the filing fee itself. Where financial statements or annual returns have gone unfiled for three consecutive financial years, directors face disqualification under Section 164(2)(a), which bars them from any company board for five years. A company that stays in default long enough can also be moved toward strike-off under Section 248.

None of this is retroactively reopened by a future scheme. Each new amnesty, if one comes, has covered only filings pending as of its own start date, so a company that could have used CCFS-2026 and didn't gains nothing automatically when the next one arrives.

If you already missed the AGM or the CCFS window

Two different problems need two different fixes, and conflating them wastes time.

A late AGM is a default under Section 96, not something ADT-1, AOC-4 or MGT-7 filings can paper over on their own. The financial statements still need board and shareholder approval before AOC-4 can be filed, so the practical route is to hold the delayed AGM as soon as the board can convene, adopt the accounts at that meeting, and then run the ADT-1, AOC-4 and MGT-7 clocks from that actual date. The Section 96 default itself is a separate compliance issue from the annual filing sequence.

A missed CCFS-2026 window has no equivalent workaround right now. The company files under the standard ₹100-a-day and multiplier rules, or waits to see whether the Ministry opens a further scheme. Waiting is a bet, not a plan, given how much the additional fee compounds by the day.

Terms this topic assumes you already know

XBRL is the structured data format certain companies must use when filing AOC-4, based on turnover and listing status rather than company size alone. A DSC is the Digital Signature Certificate every authorised signatory needs current before any MCA form can be uploaded, and DSC renewal delays are one of the more common last-mile blockers ICSI has flagged with the portal. A DIN is the Director Identification Number tied to each director, and it has to be active, not merely allotted, for filings to go through. MCA-21 V3 is the current filing portal, and it is the one where the recent processing issues have been reported.