The RoC can fine you directly now. "Nothing happens" is over.

For years, the unspoken comfort of every defaulting company was the NCLT queue. Yes, late filings technically carried penalties — but enforcement meant a tribunal already drowning in insolvency cases. In practice, small defaults sat untouched for years.

In February 2026, the MCA quietly removed that comfort. And in September, it closed the last amnesty window. If your company carries old filing defaults, read this carefully.

What changed in February 2026

Through notifications dated 10 February 2026, the central government expanded the adjudication powers of Registrars of Companies under Section 454 of the Companies Act, 2013 (and Section 76A of the LLP Act). The RoC can now decide penalties for minor statutory non-compliance directly — late financial statements, missed annual returns, statutory register lapses — without sending the matter to the NCLT.

Alongside, the Regional Directorates grew from 7 to 10, with new offices at Ahmedabad, Bengaluru and Chandigarh (effective 16 February 2026), so appeals move faster too. And from 1 January 2026, India runs 10 RoC offices — Delhi-I and II, Mumbai-I and II, Kolkata-I and II, Chandigarh, Kanpur, Noida and Nagpur — with district-level jurisdictions.

The direction is unmistakable: decriminalise the small stuff, but actually enforce it. Penalty-based, fast, and administrative.

Why this matters more than it looks

Adjudication by the RoC is a summary process. Show-cause notice on the MCA portal. Your reply. A short hearing, often virtual. Penalty order. The whole cycle can close in weeks — where the NCLT route took years or never started.

Do the maths on a typical default. AOC-4 and MGT-7 filed two years late attract additional fees of ₹100 per day per form — that's over ₹1.4 lakh in fees alone, before any adjudicated penalty on the company and officers in default. Directors should also remember: adjudication orders are public, and they surface in every serious due diligence. Our secretarial audit note explains how investors read exactly these records.

And the amnesty just ended

The Companies Compliance Facilitation Scheme, 2026 — MCA's window to regularise old filings at reduced cost — closed on 15 September 2026. MCA has said ROCs will act against companies still in default. Combined with direct adjudication powers, that is not a threat; it's a work plan.

If you used CCFS, good — keep the completion evidence safe. If you missed it, your remaining options are: file everything now with full additional fees (stops the daily meter), and if a show-cause arrives, reply properly with a professional adjudication response — grounds, precedent, mitigation. Companies that reply well routinely get penalties moderated; companies that ignore notices get the maximum.

Not sure what's pending against your CIN? Our Company Secretarial practice runs a master-data and filing-status pull for exactly this. And check your FY 2025-26 dates on the ROC annual filing calendar — this year's AOC-4 and MGT-7 deadlines have no extension announced.

The CorpCFO compliance clean-up, in one week

Here's what we do for companies in this position, in order: master-data reconciliation against MCA records; a default inventory (every form, every year, every day of delay costed); filings completed to stop the meter; adjudication replies drafted where notices exist; and a forward compliance calendar so it never recurs. Most clean-ups finish inside a week for a single company.

The worst strategy now is waiting. Every day of delay is literally ₹100 per form — and since February, there's an officer with the power to act on it.