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MCA has issued frequently asked questions (‘FAQs’) on the Companies Compliance Facilitation Scheme, 2026 (‘Scheme’), clarifying some aspects of the General Circular No. 01/2026 (‘CCFS-2026’) including covered financial years, strike-off, penalty immunity and the April 15, 2026, to July 15, 2026, window to avail the benefits.
The FAQs clarify that:
- while companies may seek strike-off by filing e-Form STK-2 at 25% concession, companies are required to complete filings up to the financial year in which business ceased. If Section 248(1) action under the Companies Act has begun, but Form STK-7 (final notice) has not been issued, pending overdue financial statements and annual returns must be filed before availing the concessional STK-2 route;
- for Sections 92 and 137 of the Companies Act, no penalty is leviable only if filings are made before notice is issued by the adjudicating officer or within 30 days of such notice. Other covered forms receive only prospective delay immunity only if filed before any show cause notice; and
- the Scheme does not cure failure to hold annual general meetings (‘AGM’). Companies may regularise overdue AGMs, adopt the financial statements with valid Unique Document Identification Numbers, and file them under the Scheme. Failing which, enforcement action after July 15, 2026, including strike-off remains possible.
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