Auditor Appointment Under Section 139: Process & ADT-1 (57 chars)

AEO Layer

Featured snippet (60 words): The appointment of a statutory auditor is governed by Section 139 of the Companies Act 2013. The board appoints the first auditor within 30 days of incorporation; thereafter shareholders appoint the auditor at the first AGM for a five-year term. Before appointment, the company must obtain the auditor's written consent and eligibility certificate, then file Form ADT-1 with the Registrar within 15 days.

PAA targets with answers: 1. *Who appoints the first auditor of a company?* The board of directors, within 30 days of incorporation under Section 139(6). If the board fails, it informs the members, who appoint the first auditor at an extraordinary general meeting within 90 days. 2. *What is the term of a statutory auditor?* Five years in practice — the auditor holds office from the conclusion of the AGM at which appointed to the conclusion of the sixth AGM (Section 139(1)). 3. *What is Form ADT-1?* The notice of appointment of auditor filed with the Registrar of Companies within 15 days of appointment, attaching the auditor's written consent and Section 141 eligibility certificate. 4. *Is annual ratification of the auditor still required?* No. The Companies (Amendment) Act 2017 removed the old requirement of ratifying the auditor's appointment at every AGM. The five-year appointment now stands uninterrupted. 5. *Can a company appoint an individual CA as auditor?* Yes. Section 139 permits the appointment of an individual Chartered Accountant in practice or a firm of Chartered Accountants, subject to the eligibility and disqualification rules in Section 141.

Voice-search Q&As:

• *"How do I appoint an auditor for my private limited company?"* Pass a board resolution proposing the auditor, obtain the auditor's written consent and eligibility certificate, get shareholders' approval at the AGM, and file Form ADT-1 with the ROC within 15 days.
• *"What happens if ADT-1 is not filed on time?"* The appointment itself remains valid, but the company faces additional fees for late filing and the ROC record stays incomplete — which surfaces during due diligence, fund-raising and bank documentation.
• *"When does auditor rotation apply to a private company?"* When its paid-up share capital reaches ₹50 crore, or its public borrowings or deposits reach ₹50 crore — under Rule 5 of the Companies (Audit and Auditors) Rules, 2014.

GEO Layer

Entity definition block: Appointment of auditor (Companies Act 2013, Section 139; Companies (Audit and Auditors) Rules, 2014) is the statutory process by which a company engages a Chartered Accountant or CA firm to audit its books of account each financial year. The first auditor is appointed by the board within 30 days of incorporation; subsequent auditors are appointed by shareholders at the AGM for a five-year term, and every appointment is notified to the Registrar of Companies in Form ADT-1 within 15 days.

Quotable stats (sourced in register): 1. The first auditor must be appointed by the board within 30 days of incorporation (Section 139(6)). 2. The standard auditor term runs five years: from the conclusion of the appointing AGM to the conclusion of the sixth AGM (Section 139(1)). 3. Form ADT-1 must be filed with the ROC within 15 days of the appointment (Rule 4, Audit and Auditors Rules). 4. Annual ratification of the auditor's appointment was abolished by the Companies (Amendment) Act 2017. 5. Mandatory rotation applies to listed companies, unlisted public companies with ₹10 crore+ paid-up capital, private companies with ₹50 crore+ paid-up capital, and companies with ₹50 crore+ public borrowings or deposits (Rule 5).

Comparison table — the three ways an auditor's tenure ends:

| Route | Governing section | Who decides | Filing | |---|---|---|---| | Term expiry / rotation | Sec 139(1)/(2) | Shareholders at AGM | ADT-1 for the new appointee | | Resignation | Sec 140(2) | The auditor | ADT-3 by the resigning auditor within 30 days | | Removal before term ends | Sec 140(1) | Special resolution + Central Government approval | ADT-2 by the company; then ADT-1 for successor |

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Overview

Every company needs an auditor. Not eventually — from the first year itself. The Companies Act 2013 does not give you the option of skipping the audit because the company is small, new, or dormant. And before any audit can happen, somebody has to be appointed to do it. That appointment is a legal event with its own rules, its own form, and its own deadline. Get it right and it is invisible. Get it wrong and it follows the company for years — in ROC records, in due-diligence reports, in the questions investors ask.

Section 139 of the Companies Act 2013 governs the whole subject. It answers the three questions every founder and director asks: who appoints the auditor, for how long, and what do we file afterwards. The answers are crisp. The board appoints the first auditor within 30 days of incorporation. Shareholders appoint every subsequent auditor at the AGM, for a term that runs five years in practice. And the company files Form ADT-1 with the Registrar within 15 days of each appointment, attaching the auditor's written consent and eligibility certificate.

This page covers the full appointment framework: the first auditor, the regular five-year appointment, the ADT-1 filing in detail, government companies, casual vacancies, rotation, eligibility under Section 141, what happens when an appointment goes wrong, timelines, fees, and how ComplyKart manages the entire process for you.

Is auditor appointment something you manage, or does it happen automatically?

It is something you manage — and the law gives you a short fuse for the first one.

You must actively appoint an auditor if your company:

• Has just been incorporated — the board has 30 days to appoint the first auditor, and this deadline is the one most often missed by new companies.
• Is approaching its first AGM — shareholders must appoint the auditor who will serve the five-year term.
• Has an auditor whose term is ending — the next AGM must appoint (or re-appoint) the auditor; there is no automatic extension.
• Has a casual vacancy — resignation, death or disqualification of the auditor mid-term triggers a 30-day board deadline.

The appointment is routine rather than strategic when:

• You are re-appointing the same auditor for a second term and rotation does not apply — the process is a resolution plus ADT-1.
• The company is small, unlisted and well under the rotation thresholds — no rotation planning needed.

The appointment becomes a board-level decision when:

• Rotation applies or is approaching — the choice of successor firm affects audit quality for the next five to ten years.
• The company is raising funds or listing — investors and bankers read the auditor's identity as a signal.
• There has been friction with the outgoing auditor — a resignation with a pointed ADT-3 on record needs careful handling.

What must be decided before appointing

Three decisions, and they are best made before the AGM notice goes out — not in the meeting itself.

Individual CA or firm? Section 139 allows both. A sole practitioner works well for small companies with simple books. A firm brings bench strength, partner review, and continuity if one partner is unavailable. Listed companies and large borrowers almost always use firms. There is no legal preference; it is a judgement call about complexity and risk.

Independence and eligibility. Before the appointment, the company must obtain the auditor's written consent and a certificate stating that the appointment, if made, will be in accordance with the conditions in Section 141 — eligibility, and none of the disqualifications. This is not paperwork for its own sake. An auditor who is indebted to the company, holds securities beyond the prescribed limit, or has a business relationship with it cannot be appointed, and an appointment made in breach can be challenged.

The term and the rotation question. The default term is five years. But if the company is in a rotation class — or will enter one during the term — the board needs to plan the handover now. Appointing a firm for five years when rotation will force a change in year three creates an avoidable mid-term disruption.

Advantages of getting the appointment right

A clean ADT-1 record from day one

Every ADT-1 filing sits on the MCA portal permanently. Lenders, investors and acquirers pull the auditor-appointment history during due diligence. A clean chain — first auditor on time, each term's ADT-1 filed within 15 days — reads as a well-run company. Gaps read as carelessness, and carelessness invites deeper questions.

The five-year term gives audit continuity

A five-year appointment means the auditor learns the business once and audits it five times. Year-one audits are expensive in effort — understanding systems, controls, related parties, revenue recognition. Years two to five are where the value compounds, because the auditor knows where the bodies are buried and can focus on what changed. Churning auditors every year destroys this.

Rotation-proofing avoids forced mid-term change

If paid-up capital is approaching ₹50 crore, or borrowings are approaching ₹50 crore, the next appointment should be made with rotation in mind. Planning the successor firm one term early turns a forced change into an orderly handover.

Fee certainty for five years

Audit fees are typically negotiated at appointment and revised annually. A proper engagement letter at appointment time — scope, fee basis, out-of-pocket terms, CARO applicability — prevents the fee disputes that are among the commonest reasons auditors resign mid-term.

Investor and lender comfort

The auditor's name on the financial statements is a signal. A reputable firm does not guarantee a clean opinion, but its presence tells a reader the audit was done by someone with reputation to lose. Companies that plan to raise debt or equity should choose the auditor with the audience in mind.

Penalty avoidance

Failure to appoint an auditor, or to file ADT-1, attracts penalties under Section 147 — on the company and on every officer in default. These are not theoretical. ROC adjudication orders for audit-related defaults are routine.

A defensible position if things go wrong

If the company later faces an NFRA enquiry, a tax scrutiny, or a shareholder dispute, the appointment file — consent, eligibility certificate, board and shareholder resolutions, ADT-1 with SRN — is the evidence that the audit was properly constituted. Companies that cannot produce it start every defence on the back foot.

Documents required

From the company:

• Board resolution proposing the auditor's appointment (for the first auditor) or recommending it to shareholders
• Shareholders' resolution at the AGM (ordinary resolution for appointment)
• PAN and incorporation details for the ADT-1 form

From the auditor:

• Written consent to act as auditor
• Certificate under Section 141 confirming eligibility and absence of disqualifications
• Firm registration number (if a firm), or membership number (if an individual)
• Peer review certificate details (relevant for certain classes of companies)
• Engagement letter (good practice, though not a statutory filing)

ADT-1 — the filing, step by step

This is the section most people come to this page for, so here it is in full.

What it is. Form ADT-1 is the notice to the Registrar of Companies that the company has appointed (or re-appointed) its statutory auditor. It is filed by the company — not by the auditor — within 15 days of the appointment, under Rule 4 of the Companies (Audit and Auditors) Rules, 2014.

What goes in. The form captures the auditor's identity (individual membership number or firm registration number), the financial year from which the appointment takes effect, and the term. Attachments: the auditor's written consent letter and the Section 141 eligibility certificate. Both are mandatory attachments — the form cannot be properly filed without them.

Who signs. The form is digitally signed by a director (or manager/secretary) of the company and certified by a practising professional — a Chartered Accountant, Company Secretary or Cost Accountant in whole-time practice.

The 15-day clock. The clock starts on the date of appointment — the date of the AGM resolution, or the board resolution for the first auditor. Fifteen days is short. Companies that hold the AGM on 30 September and then go quiet until October routinely miss it. The practical discipline: prepare the ADT-1 papers before the AGM, and file within a week of the meeting.

What delay costs. Late filing attracts additional fees on the MCA portal, calculated per day of delay. Beyond money, a missing or late ADT-1 leaves the ROC record showing no auditor — which is exactly the kind of gap a diligence team flags.

First auditor and ADT-1. Yes, ADT-1 is filed for the first auditor too, within 15 days of the board resolution appointing them. This is a common miss: companies assume the first appointment is somehow informal. It is not.

Re-appointment and ADT-1. Every fresh appointment — including re-appointment of the same auditor for a second five-year term — needs its own ADT-1. The form is per appointment, not per auditor.

The 5-year term — how it actually works

Section 139(1) says the auditor holds office "from the conclusion of that meeting till the conclusion of its sixth annual general meeting" — the AGM at which appointed, plus five more. In practice, everyone calls this a five-year term, covering five financial years.

No annual ratification. Until 2017, companies had to get the auditor's appointment ratified at every AGM — an annual ritual that added nothing. The Companies (Amendment) Act 2017 deleted it. The five-year appointment now runs uninterrupted. If your company's older board minutes still contain ratification resolutions out of habit, they are harmless but unnecessary.

What happens at the end of the term. The term ends at the conclusion of the sixth AGM. The next AGM must appoint the auditor for the following term — either re-appointing the same auditor (if rotation does not apply) or appointing a new one. There is no holdover provision: if the AGM fails to appoint anyone, the company is in default from that day.

Can the term be shorter? The Act sets the maximum, not a mandatory minimum in every case. An auditor appointed to fill a casual vacancy caused by resignation holds office only until the next AGM. But for regular appointments, the five-year term is the norm, and departing from it needs a reason.

Re-appointment limits. Re-appointment is freely permitted where rotation does not apply — a private company under the thresholds can re-appoint the same firm indefinitely. Where rotation applies, an individual gets one five-year term and a firm gets two consecutive five-year terms, followed by a five-year cooling-off period during which neither the auditor nor a firm sharing a common partner can be appointed.

The first auditor — the 30-day rule

Section 139(6): the board of directors must appoint the first auditor within 30 days of incorporation. This is the single most-missed auditor deadline in Indian company law, because new companies are busy with bank accounts, GST and hiring, and the audit feels like next year's problem.

If the board misses the 30 days, it must inform the members, who appoint the first auditor at an extraordinary general meeting within 90 days. The first auditor holds office until the conclusion of the first AGM — a shorter stint than the regular five-year term.

Practical reality: most companies appoint the first auditor at the first board meeting itself, alongside the registered-office and share-allotment resolutions. It costs nothing extra to do it early and removes a deadline from the list.

Government companies — the CAG route

For government companies, the appointment machinery is different. The first auditor is appointed by the Comptroller and Auditor-General of India within 60 days of incorporation (Section 139(5)). If the CAG does not appoint within 60 days, the board appoints within the next 30 days — and informs the members, who appoint at an EGM within 60 days if the board also fails.

For subsequent years, the CAG appoints the auditor within 180 days of the commencement of each financial year (Section 139(7)). Government companies also face supplementary audit by the CAG under Section 143(5)–(7) — a second layer of audit over and above the statutory audit.

Casual vacancy — when the auditor's chair empties mid-term

Section 139(8) governs casual vacancies — the office falling vacant because of resignation, death, or disqualification. The board must fill the vacancy within 30 days.

The resignation trap: where the vacancy is caused by the auditor's resignation, the board's appointee must be approved by the company at a general meeting convened within three months of the board's recommendation, and the auditor so appointed holds office only until the conclusion of the next AGM — not a full five-year term. Companies that treat a resignation replacement as a normal five-year appointment get this wrong.

The resigning auditor's own duty: the auditor who resigns must file Form ADT-3 with the company and the ROC within 30 days of resignation, stating the reasons and relevant facts — a public document. (Our dedicated page on auditor resignation covers the ADT-3 process and the fraud-reporting duty in full.)

Auditor rotation — who must rotate

Section 139(2) read with Rule 5 of the Audit and Auditors Rules prescribes rotation for:

• All listed companies
• All unlisted public companies with paid-up share capital of ₹10 crore or more
• All private limited companies with paid-up share capital of ₹50 crore or more
• All companies — public or private — with public borrowings from banks or financial institutions, or public deposits, of ₹50 crore or more

One Person Companies, small companies and dormant companies are expressly excluded.

Tenure limits: an individual auditor — one term of five consecutive years. An audit firm — two consecutive terms of five years each. After that, a five-year cooling period during which the auditor, and any firm with a common partner, cannot be appointed.

The transition trap: a private company that crosses ₹50 crore paid-up capital mid-term enters the rotation regime. The ADT-1 filings create a public tenure record, so the transition cannot be fudged — plan the successor appointment at least a year ahead.

Eligibility and disqualifications — Section 141

Only a Chartered Accountant in practice — an individual, or a firm where the majority of partners are CAs in practice — can be appointed. Section 141 then lists disqualifications: a body corporate (other than an LLP); an officer or employee of the company; a person who is a partner, or in the employment, of an officer or employee of the company; a person indebted to the company beyond the prescribed amount; a person who has given a guarantee for a third party's indebtedness to the company beyond the prescribed amount; a person with prescribed business relationships; a person holding securities of the company beyond the prescribed limit. The auditor must also not have been convicted of fraud with a ten-year lookback, and must stay within the ceiling of 20 company audits (excluding OPCs, dormant companies, small companies and private companies with paid-up capital below ₹100 crore).

Changing the auditor — the three legal routes

An auditor's tenure can end three ways, and they are very different exercises:

Route 1 — Term expiry and fresh appointment. The cleanest route. At the AGM, shareholders appoint the new auditor (or re-appoint the old one), and the company files ADT-1 within 15 days. If the retiring auditor is not being re-appointed, Section 140(4) requires special notice — and the retiring auditor has the right to make a representation, which the company must circulate.

Route 2 — Resignation. The auditor resigns, files ADT-3 within 30 days, and the company fills the casual vacancy. Covered in detail on our auditor resignation page.

Route 3 — Removal before term expiry. Section 140(1): the auditor can be removed before the term ends only by a special resolution of the company, after obtaining the previous approval of the Central Government. The company applies in Form ADT-2 to the Regional Director within 30 days of the board resolution proposing removal, and the auditor must be given a reasonable opportunity of being heard. This is deliberately hard — the law does not want managements sacking auditors who ask uncomfortable questions.

How long does the appointment process take?

• First auditor: a single board meeting — the appointment itself takes a day; ADT-1 filing within 15 days.
• Regular AGM appointment: the shareholder resolution at the AGM, then ADT-1 within 15 days. Allow a week of preparation before the AGM (consent, certificate, engagement letter).
• Casual vacancy: board appointment within 30 days of the vacancy; where caused by resignation, shareholder approval at a general meeting within three months.
• Removal (ADT-2 route): two to four months end to end — board resolution, ADT-2 to the Regional Director, hearing, approval, then special resolution and ADT-1 for the successor.

Fees — what auditor appointment costs

The appointment itself has two cost layers: the MCA filing fee for ADT-1 (a few hundred rupees, plus professional certification charges) and the professional fee for managing the process. The audit fee — the real money — is negotiated separately in the engagement letter and depends on turnover, transaction volume, number of locations, group structure and CARO applicability. As a rough frame: small private companies typically see annual audit fees from the tens of thousands of rupees; mid-size companies with multi-location operations run into lakhs; listed companies and large groups run into tens of lakhs and beyond. [NEEDS VERIFICATION: fee bands at publish time.]

How ComplyKart helps

What we do:

• Eligibility check — we verify the proposed auditor's credentials, peer-review status and Section 141 eligibility before any resolution is passed.
• Documentation — we draft the board and shareholder resolutions, obtain the consent letter and eligibility certificate in the right format, and prepare the engagement letter.
• Filing — we file ADT-1 within the 15-day window, with proper attachments and professional certification, and share the SRN for your records.
• Calendar management — we track the term: first auditor deadline, AGM appointment dates, rotation triggers, and casual-vacancy clocks, so no deadline is ever discovered after it has passed.
• Rotation planning — for companies approaching the Rule 5 thresholds, we plan the successor appointment a year ahead.

What we will not do:

• We will not recommend a specific auditor as "the best" — the choice of auditor is the board's, and we present verified options with the facts.
• We will not backdate resolutions or filings — the 15-day and 30-day clocks run from the actual event dates.
• We will not file ADT-1 without the auditor's genuine consent and eligibility certificate.

What happens after the appointment

Within 30 days of appointment, the auditor should issue the engagement letter and begin planning the audit — understanding the business, assessing risk, and setting the audit programme. The company, for its part, should ensure the auditor has access to the books, the accounting system, and the key people. The first real milestone is the audit itself, culminating in the audit report that goes to the board and then to shareholders at the AGM. The ADT-1 SRN goes into the company's statutory records alongside the resolutions.

Recurring compliance

• Each AGM: appoint or re-appoint the auditor as the term requires; file ADT-1 within 15 days of each appointment.
• Rotation monitoring: track paid-up capital and borrowings against the Rule 5 thresholds every year — crossing a threshold mid-term changes the next appointment.
• Casual vacancy watch: any resignation, death or disqualification starts the 30-day board clock immediately.
• DIR-3 KYC note: directors' KYC is triennial (next due 30 June 2028) — unrelated to auditor appointment, but it shares the AGM-season calendar, so we track it together.

Common mistakes companies make

1. Missing the 30-day first-auditor deadline. The commonest miss. Appoint at the first board meeting and be done with it. 2. Filing ADT-1 late — or never. The appointment is valid, but the ROC record is incomplete, and late fees accumulate. 3. Skipping the consent and eligibility certificate. The Act requires them before appointment; an appointment without them is procedurally defective. 4. Assuming the old auditor continues automatically. There is no holdover. No appointment at the AGM means no auditor from the conclusion of that AGM. 5. Ignoring rotation until it bites. Crossing ₹50 crore paid-up capital without a succession plan forces a rushed change. 6. Appointing a disqualified person. Section 141 disqualifications are not technicalities — indebtedness and business-relationship bars are tested in NFRA proceedings. 7. Treating a resignation replacement as a five-year term. It holds office only until the next AGM, and needs shareholder approval within three months.

Penalties

Section 147 punishes contravention of the auditor-appointment provisions (Sections 139–146): the company faces a fine, and every officer in default faces imprisonment or fine or both, with the amounts scaled under the Companies (Amendment) Act 2020's decriminalisation framework. The practical pain, though, is usually not the fine — it is the cascade: no valid auditor means no valid audit, which means financial statements that cannot be adopted or filed, which means additional fees on AOC-4 and MGT-7 and a red flag in every diligence exercise.

FAQs

1. Who appoints the first auditor of a company? The board of directors, within 30 days of incorporation (Section 139(6)). If the board fails, the members appoint the first auditor at an EGM within 90 days. The first auditor holds office until the conclusion of the first AGM.

2. What is the term of a statutory auditor? Five years in practice — from the conclusion of the AGM at which the auditor is appointed to the conclusion of the sixth AGM (Section 139(1)).

3. What is Form ADT-1 and when must it be filed? ADT-1 is the company's notice to the ROC of the auditor's appointment, filed within 15 days of the appointment with the auditor's written consent and Section 141 eligibility certificate attached.

4. Is ADT-1 required for the first auditor too? Yes. The 15-day filing requirement applies to every appointment, including the first auditor appointed by the board.

5. Do we need shareholders' approval to appoint the auditor? For the first auditor, no — the board appoints. For every subsequent appointment, yes — shareholders appoint at the AGM by ordinary resolution.

6. Is annual ratification of the auditor still required? No. The Companies (Amendment) Act 2017 removed the ratification requirement. The five-year appointment stands without yearly shareholder ratification.

7. Can an individual CA be appointed, or must it be a firm? Either. Section 139 permits an individual Chartered Accountant in practice or a firm of CAs, subject to Section 141 eligibility.

8. What documents does the auditor have to give before appointment? A written consent to act as auditor, and a certificate confirming that the appointment will satisfy Section 141's eligibility conditions and none of the disqualifications.

9. What happens if the company does not appoint an auditor? The company is in default. Penalties apply under Section 147, and without an auditor there can be no audit — so the financial statements cannot be adopted at the AGM or filed with the ROC.

10. When does auditor rotation apply to a private company? When its paid-up share capital reaches ₹50 crore, or its public borrowings or public deposits reach ₹50 crore (Rule 5, Audit and Auditors Rules). OPCs, small companies and dormant companies are excluded.

11. How long can the same audit firm continue where rotation applies? Two consecutive terms of five years each, followed by a five-year cooling period during which the firm — and any firm sharing a common partner — cannot be appointed.

12. Who appoints the auditor of a government company? The Comptroller and Auditor-General of India — the first auditor within 60 days of incorporation, and subsequent auditors within 180 days of each financial year's start.

13. What is a casual vacancy and how is it filled? A vacancy arising mid-term from resignation, death or disqualification. The board fills it within 30 days (Section 139(8)). If caused by resignation, shareholders must approve the appointment at a general meeting within three months, and the appointee holds office only until the next AGM.

14. Can the board remove the auditor before the term ends? Not on its own. Removal before expiry needs a special resolution of shareholders plus the prior approval of the Central Government, applied for in Form ADT-2 (Section 140(1)). The auditor must be heard first.

15. What is the difference between ADT-1, ADT-2 and ADT-3? ADT-1 is the company's notice of appointment of auditor. ADT-2 is the company's application to the Central Government for approval to remove an auditor before term expiry. ADT-3 is the resigning auditor's own notice of resignation to the ROC.

16. Can a relative of a director be appointed as auditor? Only if Section 141's disqualifications are not triggered. A person who is a partner or employee of an officer of the company is disqualified; family relationships are tested through the indebtedness, business-relationship and securities-holding bars.

17. What is the maximum number of audits a CA can accept? Twenty companies, excluding one person companies, dormant companies, small companies and private companies with paid-up capital below ₹100 crore (Section 141(3)(g)).

18. Does the auditor need to be changed when the company converts (e.g. private to public)? Not automatically — the appointment continues. But conversion can trigger rotation thresholds (a public company faces the ₹10 crore capital test instead of ₹50 crore), so the next appointment must be planned accordingly.

19. What if the AGM is not held — who appoints the auditor? Failure to hold the AGM is itself a default with its own penalties. The appointment should be made at the delayed AGM once held; in the interim the company has no validly appointed auditor for the new term, which compounds the compliance failure.

20. Can ComplyKart file ADT-1 for an appointment made last year? Yes — with additional fees for the delay. We file it with the correct (actual) appointment date; backdating is not an option, and we will tell you the late-fee position upfront.

Sources

• Companies Act 2013, Sections 139 (appointment), 140 (removal/resignation), 141 (eligibility), 147 (penalties) — bare Act text
• Companies (Audit and Auditors) Rules, 2014 — Rules 4 (ADT-1), 5 (rotation classes), 13 (fraud reporting)
• Companies (Amendment) Act 2017 — removal of annual ratification
• ICAI Guidance Note on Section 139 reporting aspects
• NFRA circulars on auditor obligations

We re-check the MCA filing forms and fee schedules before every engagement, and this page is reviewed whenever the Audit and Auditors Rules are amended.