MCA Circular 06/2026: CRA-4 Cost Audit Report Now Fee-Free Till 31 December 2026

Three days after the MCA gave companies breathing room on AOC-4 and MGT-7, it came back with a second circular for a smaller, quieter set of companies. If your company falls under cost audit, this one is yours. On 27 October 2026, the Ministry of Corporate Affairs issued General Circular No. 06/2026: your cost audit report filing — Form CRA-4, in XBRL format, for the financial year 2025-26 — can be filed up to 31 December 2026 without any additional fee.

That sentence has travelled across compliance news sites as "CRA-4 extended". Read it that way and you will get two things wrong, and both cost money. CRA-4 never had one fixed date for every company, so no single date moved. And the circular waives the additional fee, not the filing itself — after 31 December, the additional fee is counted back from your original due date, not from 1 January.

Short answer: Under MCA General Circular No. 06/2026 dated 27 October 2026, a company covered by cost audit may file Form CRA-4 for FY 2025-26 up to 31 December 2026 without paying additional fees. The normal filing fee still applies, and the 30-day filing clock under Section 148(6) still runs from the date the company receives the cost audit report.

What CRA-4 actually is

Most companies file AOC-4 for financial statements and MGT-7 for the annual return. CRA-4 is a different filing for a different audit. Where a company is covered by cost audit under Section 148 of the Companies Act, 2013, a cost auditor examines its cost records and reports in Form CRA-3. The company then sends that report to the Central Government in Form CRA-4, in XBRL format, along with full information and explanation on every reservation or qualification the auditor raised. It is not a summary, and for covered companies it is not optional.

One practical point first: the CRA-2 and CRA-4 forms were substituted by the Companies (Cost Records and Audit) Amendment Rules, 2025, effective 14 July 2025. If your team is working from an old form copy, stop. File on the current form and its current validations, or the portal will do the stopping for you.

Does your company even file CRA-4?

This is the question the news posts skip, and it matters because most companies never file CRA-4. Cost audit is not a size test alone. It is a two-step test under the Companies (Cost Records and Audit) Rules, 2014, and both steps use the immediately preceding financial year's turnover.

Step one is cost records. Rule 3 lists specified goods and services in two tables — Table A for regulated sectors, Table B for the rest. A company engaged in those goods or services must generally maintain cost records if its overall turnover was ₹35 crore or more in the immediately preceding financial year. That test means records, not yet audit.

Step two is cost audit, and Rule 4 sets a higher bar with two limbs that must both pass:

Take a Table B manufacturer with overall turnover of ₹90 crore and covered-product turnover of ₹40 crore. Records: yes. Cost audit: no — the ₹100 crore overall limb fails, so the company keeps cost records and never files CRA-4. At ₹120 crore overall and ₹38 crore from covered products, both limbs pass and cost audit applies, unless a specific exception saves it — the two worth checking are export revenue in foreign exchange exceeding 75% of total revenue, and operations from a special economic zone. An exception from audit does not automatically end the records duty, so check each duty on its own facts. Companies classed as micro or small enterprises are excluded from the Rule 3 records requirement in the first place. And if you are unsure which table your product sits in, that mapping is the whole exercise: the rule works off the exact product description and, where specified, the Customs Tariff heading — not off your industry label.

The clock that starts at your door

Here is the trickiest part of CRA-4, and the part most deadline lists get wrong. Your CRA-4 due date is not 31 December, and it was never a date printed in a calendar. Section 148(6) of the Companies Act and Rule 6(6) of the Cost Records and Audit Rules say the company must furnish the report within 30 days from the date it receives a copy of the cost audit report. The clock starts on receipt.

Think of it like a courier delivery. The sender posting the parcel does not start your countdown. The days start when the parcel reaches your door and you sign for it. The auditor's side has its own deadline — Rule 6(5) requires the auditor to forward the report to the Board within 180 days of the financial year closing, which for a March year-end ordinarily lands in late September. But your 30 days run from when the company actually receives the report. Keep the receipt evidence with the filing papers. If the receipt date is ever questioned, that evidence is your answer.

So a company that received its FY 2025-26 cost audit report on 20 September 2026 had an ordinary CRA-4 date of 20 October 2026 — weeks before this circular existed. That company was already late when Circular 06/2026 arrived. The circular does not rewrite that history. It says a filing made up to 31 December 2026 will not attract additional fees. The late filing is forgiven its fee, not its lateness.

What Circular 06/2026 changes — and what it does not

The circular is short, and it helps to read it paragraph by paragraph rather than through headlines. Its file number is Policy-17/52/2020-CL-V, issued after stakeholder representations asking for more time on cost audit report filings.

Paragraph 1 is the relief: any filing of CRA-4 in XBRL format for FY 2025-26 made up to 31 December 2026 will not attract payment of any additional fees. Paragraph 2 is the sting: filings made after the circular's currency attract all fees, including additional fees, under the Companies (Registration Offices and Fees) Rules, 2014 — counted from the date the filing was actually due under Rule 6(6). That is the original, receipt-based due date. Not 1 January. Not the date the circular expires. Your own 30-day date.

Three things the circular does not do. It does not extend the 30-day rule itself. It does not waive the normal filing fee. And it does not touch any other form. CRA-2, the appointment intimation, is a separate filing with its own clock: within 30 days of the Board meeting or 180 days from the start of the financial year, whichever is earlier. AOC-4 and MGT-7 were covered three days earlier by a different circular — General Circular No. 05/2026, which I covered in the MCA annual filing extension post. CRA-4 was not in that circular's list of forms, which is exactly why this second circular exists. Do not assume a circular covers your form because it covered your neighbour's.

The fee maths if you miss 31 December

Stay with the company that received its report on 20 September 2026. Its ordinary due date was 20 October. File on 15 January 2027 and the additional fee counts every day from 21 October: 11 days left in October, 30 in November, 31 in December, 15 in January. That is 87 days. At ₹100 per day, the additional fee alone is ₹8,700 for that one form — on top of the normal filing fee. File on 31 December instead and the additional fee is nil. Every week of drift past 31 December adds ₹700 to that form.

Remember too that the fee is per form, and paying it does not convert a late filing into a timely one. If your cost audit report carries qualifications, the explanations that travel with CRA-4 deserve the same care as the fee date — a rushed explanation filed on 30 December to beat the window can create a worse problem than the fee it saved.

Five mistakes I see around CRA-4

First, copying another company's due date from a deadline list. Your date is receipt-based; theirs is not yours. Second, treating 31 December as the statutory due date. It is the last fee-free date under this circular, not the date Rule 6(6) sets. Third, filing CRA-4 before the Board has considered the report, especially its reservations and qualifications. Fourth, assuming the statutory auditor under Section 139 can double up as cost auditor. They cannot. Fifth, leaving XBRL validation to the last day — a validation failure on 31 December is a 1 January filing, with fees counted back to October.

What to do this week

Pull three things together now: the cost audit report's receipt date, the Board minutes showing the report was considered, and your draft explanations for every reservation or qualification. Work out your own Rule 6(6) date from the receipt date and mark 31 December 2026 as the fee-free boundary, not the deadline. Run the XBRL validation early, while a failure is still fixable inside the window. And if your company files AOC-4 and MGT-7 too, keep the two circulars apart in your tracker — the annual filing page carries the AOC-4 and MGT-7 dates under Circular 05/2026, while CRA-4 runs on this circular's terms. One tracker, two rules, no crossed wires.

The MCA has now given cost audit filings the same kind of fee relief it gave annual filings three days earlier. Use it the way it is written: file inside the window, keep your receipt evidence, and do not let a fee waiver talk you into treating a filing as if it had no deadline at all.

Frequently asked questions

Does Circular 06/2026 extend my 30-day CRA-4 deadline?

No. It waives the additional fee for FY 2025-26 filings made up to 31 December 2026. The 30-day period under Section 148(6) and Rule 6(6) still runs from receipt of the cost audit report, and filings after the window attract additional fees counted from that original due date.

Does the circular cover CRA-2 as well?

No. The circular names CRA-4 only. CRA-2, the intimation of the cost auditor's appointment, keeps its own deadline — within 30 days of the Board meeting or 180 days from the start of the financial year, whichever is earlier.

I already paid additional fees on a late CRA-4 before this circular. Do I get a refund?

The circular says nothing about refunding additional fees already paid. It waives additional fees for filings made up to 31 December 2026. Do not assume a refund is available; if the amount is large, take advice on whether any separate remedy exists rather than treating the circular as one.

My company keeps cost records but is below the cost audit thresholds. Does this circular matter to me?

No filing arises for you under CRA-4, so the circular changes nothing for you. Keep maintaining the records — the records duty and the audit duty are separate tests, and falling below the audit thresholds does not end the records duty.

Does the circular change the XBRL format or the form itself?

No. CRA-4 remains the Cost Audit Report in XBRL format. Note separately that the CRA-2 and CRA-4 forms were substituted with effect from 14 July 2025, so file on the current form version and run its validations early.

For the wider filing season, the secretarial audit applicability guide covers the other audit that trips companies up at this time of year, and the compliance fee calculator can help you work out what a filing season actually costs.