Most people know about the ₹100 a day. Fewer know that the additional fee is the mildest of the consequences, and the only one that is purely financial.
Here is the full picture, in the order it tends to arrive.
1. The additional fee — immediate, automatic, uncappable
₹100 per day, per form, from the day after the due date.
Three features make it worse than it sounds:
There is no upper limit. The ceiling that existed before July 2018 is gone. A form five years late accrues around ₹1,82,500 on its own.
It is per form. AOC-4 and MGT-7 both late means ₹200 a day. Add AOC-4 CFS and ADT-1 and you are at ₹400 a day for a single financial year.
It is per year of default. Three years of missed filings is three sets of forms, each accruing separately from its own due date. This is the part that turns a manageable problem into a six-figure one.
There is no application to waive it and no officer with discretion to reduce it. The system calculates it and it is paid with the form.
| Days late | 1 form | 2 forms | 4 forms |
|---|---|---|---|
| 30 | ₹3,000 | ₹6,000 | ₹12,000 |
| 90 | ₹9,000 | ₹18,000 | ₹36,000 |
| 365 | ₹36,500 | ₹73,000 | ₹1,46,000 |
| 1,095 (3 yrs) | ₹1,09,500 | ₹2,19,000 | ₹4,38,000 |
2. Penalties under Section 137 — separate from the fee
The additional fee is a filing charge. It is not a penalty, and paying it does not discharge the default.
Section 137 provides for penalties on the company and on its officers in default — which means the directors, the CFO and the company secretary — for failure to file financial statements. These are levied through adjudication proceedings by the Registrar, and they are additional to the additional fee.
The practical point: paying ₹1,09,500 in additional fees does not close the matter. It gets the form filed. Whether the Registrar proceeds on the underlying default is a separate question.
3. Director disqualification
Section 164(2) disqualifies a director where the company has failed to file financial statements or annual returns for three continuous financial years.
The consequences follow the person, not only the company:
- disqualification for five years;
- it applies to every other company on whose board that person sits, not merely the defaulting one;
- the DIN is typically deactivated, which blocks filings across all of those companies.
This is the consequence that turns a dormant company nobody thought about into a live problem. A director of six companies, one of which is a defunct venture from years ago, can find themselves unable to sign anything for any of them.
Restoring the position — condonation, appeal, or in some cases proceedings before the NCLT — costs far more than the filings ever would have.
4. Strike-off
Where a company has not been carrying on business, or has not filed for a sustained period, the Registrar may initiate removal of its name from the register under Section 248.
For a company that is genuinely finished, that may be a convenient outcome. For one that holds assets, bank accounts, contracts, intellectual property or a name you care about, it is not. Restoration requires an application to the NCLT — expensive, slow, and not guaranteed.
5. The commercial consequences nobody warns you about
These do not appear in the Act and they cost the most in practice.
Bank finance. Lenders pull MCA filings during due diligence. Missing filings raise questions that delay sanction, and the additional fee sitting on the ledger is not a good look on a credit file.
Due diligence in a transaction. Every investor, acquirer and strategic partner runs a search on the MCA portal in the first week. Missing filings are the fastest way to lose negotiating leverage, and they routinely end up as indemnities in the share purchase agreement.
Tenders and empanelment. Government and large corporate tenders frequently require filed financial statements. Not filed means not eligible, regardless of merit.
Your own record. Filings are public. Anyone — a customer, a competitor, a prospective employee — can look at your company’s compliance history in thirty seconds.
The one route out, and it closes on 31 August 2026
CCFS-2026 allows companies to complete pending annual filings at normal fees plus only 10% of the additional fee, with immunity from prosecution where the filing is made before an adjudicating officer issues a notice, or within 30 days of one.
On ₹2,19,000 of accumulated additional fees, that is a saving of roughly ₹1,97,000 — and, in eligible cases, closure of the exposure rather than merely the filing.
The scheme was extended once, from 15 July to 31 August 2026. Assume it will not be extended again.
If your company is behind, read the full explanation here, or work out your own number.
If you are already late
Do not wait for a notice. Filing before a notice arrives materially improves your position — under CCFS-2026 explicitly, and in adjudication generally. Filing after one narrows your options.
Deal with the oldest year first. It is accruing the most and it is the one that counts towards the three-year disqualification trigger.
Check whether accounts are actually adopted. You cannot file AOC-4 without financial statements adopted at a general meeting. If several years are outstanding, the accounting and audit work has to happen first, and that is the step that runs out of time.
Check every director’s DIN status while you are at it. DIR-3 KYC defaults deactivate DINs independently, and a deactivated DIN will stop the filings you are trying to make.
Find out where you stand — free
Enter your financial year end and AGM date. Our calculator shows every deadline you owe and exactly what you already owe in additional fees.
Calculate my late fees → — 30 seconds, no sign-up.
Or send us your CIN. We will confirm what is outstanding, what it costs under CCFS-2026 and what it costs after, in writing, at no charge.
Send my CIN → · +91 92898 96117, Monday to Saturday, 10:00 to 19:00.
General information, not advice for your company. Penalties, disqualification and strike-off depend on facts specific to the company and the years in default, and the position on any scheme is as notified by the MCA. Where a default is significant, take professional advice before filing — the order in which things are done matters.
