ADT-1 Filing Now Mandatory for First Auditor Appointment 

The Ministry of Corporate Affairs (MCA) has notified a key amendment that changes how companies must comply with auditor appointment filings. As per G.S.R. 359(E) dated May 30, 2025, the Companies (Audit and Auditors) Amendment Rules, 2025 will take effect on July 14, 2025 and with it, Form ADT-1 filing becomes mandatory for all first auditor appointments, including those made by the Board of Directors.

This marks a significant shift from the previous exemption that allowed companies to skip ADT-1 filing if the Board appointed the first auditor within 30 days of incorporation.

What Has Changed?

The recent amendment marks a major shift in how companies must report the appointment of their first auditor. Here’s a quick breakdown of the rules before and after July 14, 2025.

Before July 14, 2025 (Old Rule)

Under Rule 4(2) of the Companies (Audit and Auditors) Rules, 2014, if the Board of Directors appointed the first auditor, there was no need to file Form ADT-1.

• ADT-1 filing was only mandatory if the shareholders appointed the first auditor (usually via EGM).
• Filing was also required for subsequent auditor appointments at the AGM.

After July 14, 2025 (New Rule)

ADT-1 filing is now mandatory even when the Board appoints the first auditor.

The MCA has updated the ADT-1 form, which now includes a clear dropdown for:

• “First auditor by the Board of Directors”
• “First auditor by Members”
•  “First auditor by C&AG”

Example:

ABC Pvt Ltd. was incorporated on July 15, 2025. The Board appointed the first auditor on July 20, 2025. Under the new rules, ABC Pvt Ltd. must now file Form ADT-1 with the ROC by August 4, 2025 (i.e., within 15 days of the appointment), even though the appointment was made by the Board.

Who Must Comply with the New ADT-1 Filing Rule? 

The amended rule applies to a wide range of companies. The following entities are now required to file Form ADT-1 for first auditor appointments:

• All newly incorporated companies (both private and public) on or after July 14, 2025
• Companies where the Board of Directors appoints the first auditor within 30 days of incorporation (previously exempt)
• Companies where the first auditor is appointed by:
• Members in an EGM (if the Board fails to appoint)
• Comptroller and Auditor General (C&AG) in the case of government companies (already mandatory)

Quick Comparison: Before vs. After Amendment

Here’s a side-by-side comparison to help you understand how the ADT-1 filing requirements have changed with the new amendment:

ADT-1 Due Date and Penalty for Non-Filing

Timely filing of Form ADT-1 is essential to avoid late fees and penalties. As per MCA guidelines, the form must be filed within 15 days from the date of appointment of the auditor.

If the company fails to file ADT-1 within the due date, the following penalty structure applies:

Note: These penalties are calculated based on the prescribed filing fee under the Companies (Registration Offices and Fees) Rules, 2014.

What Companies Need to Do Now

To ensure compliance with the amended rules, companies must take the following immediate steps:

File ADT-1 for First Auditor Appointed by the Board

• Previously optional, this filing is now mandatory even when the Board of Directors appoints the first auditor.
• Companies must submit Form ADT-1 to the Registrar of Companies (ROC) using the revised format, which clearly captures the nature of the appointment.

Adhere Strictly to the Filing Deadline

• Form ADT-1 must be filed within 15 days from the date of the auditor’s appointment by the Board.
• Missing this deadline could result in penalties, late fees, or compliance flags from the ROC.

Update Internal Compliance Processes

• Companies should align their secretarial and compliance workflows to reflect this regulatory change:
• Notify your company secretary and legal teams about the new ADT-1 requirement for Board-appointed auditors.
• Prepare updated board resolution templates in advance to speed up documentation and filings. 

Final Takeaway

If your company is being incorporated or appointing its first auditor on or after July 14, 2025, ensure Form ADT-1 is filed — no exceptions. Ignoring this change could lead to penalties or non-compliance issues.

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