Cost Audit Report – Form CRA 4 Due Date Extension (2025 Update)

The Ministry of Corporate Affairs (MCA) has issued a General Circular No. 07/2025 regarding the filing of CRA-4 (Cost Audit Report in XBRL format). This update comes in response to requests from stakeholders seeking an extension of the deadline for filing the Cost Audit Report. The circular specifies that no additional fees will be charged for filings made up until December 31, 2025 for the financial year 2023-2024. This relaxation applies to the CRA-4 form filings made through the MCA's V3 portal. However, any filings made after this period will attract fees, including additional charges, as specified under the Companies (Registration Offices and Fees) Rules, 2014.

Synopsis of the 2025 Update:

In light of the updated system, the MCA has provided a relaxation of additional fees and extended the deadline for submitting Form CRA-4 for the financial year 2023-2024.

• Extended Filing Date: The cost audit report for the financial year 2023-2024 should be submitted by the cost auditor to the Board of Directors by November 30, 2025. Submissions made by this deadline will not be considered a violation of Rule 6(5) of the Companies (Cost Records and Audit) Rules, 2014.
• Filing Form CRA-4: Once the cost audit report is submitted to the board, the company must file the e-Form CRA-4 with the Ministry of Corporate Affairs within 30 days of receiving the report.

Note: The Ministry of Corporate Affairs (MCA) has also announced that the additional fee waiver for filing Form CRA-4 for the financial year ending 31st March 2025 is currently under development. These changes are expected to be finalized shortly.

Companies whose filing due dates have either already passed or fall within this period are advised to keep track of the forthcoming changes. It is recommended that companies plan their filing schedules in accordance with these updates to avoid additional fees once the changes are fully implemented.

Cost Audit

Cost audit is the process of verification of cost accounts of a company to determine the accuracy of cost accounting records. Cost audit will ensure that whether the cost accounting records are in track with the costing principles, objectives, plans, and procedures. The audit usually involves the following:

• Verification of accuracy of costing records
• Detection of errors in the cost records
• Checking of cost books, accounts, and records

Also read: Cost Records and Cost Audit Applicability

Governing Law

Section 148 of the Companies Act, 2013 lays out the provisions and requirements concerning Cost Records and Cost Audit applicability. Rule 3 of the Companies (Cost Records and Audit) Rules, 2014 identifies the companies that are required to keep Cost Records, undergo a Cost Audit, and submit Cost Audit Report.

Companies Required Conducting a Cost Record Audit

The following entities are required to file the Cost Audit Report in Form CRA-4 to Government:

• Regulated sectors dealing with specified goods/services which overall annual total turnover from all products/services is Rs.50 Crore or more
• Regulated sectors dealing with specified goods/services which aggregate turnover from the individual product/service is Rs.25 Crore or more
• Non-regulated sectors dealing with specified goods/services and overall annual total turnover from all products/services is Rs.100 Crore or more
• Non-regulated sectors dealing with specified goods/services aggregate turnover from the individual product/service is Rs.35 Crore or more

To know more about the Regulated and Non-regulated sectors, go through the document attached here.

Exemption from Conducting a Cost Record Audit

The following companies are exempted from Conducting a Cost Record Audit

• The company’s export revenue in foreign exchange exceeds 75% of total revenue
• The company operates from a Special Economic Zone (SEZ)
• The company is engaged in the production of electricity through Captive Generating Plant

Applicable Forms - Cost Audit Report

Form CRA-1

Forms in which cost records shall be maintained. This form CRA-1 prescribes the form in which cost records will be maintained and detailed information about the cost element and their treatments etc.

Form CRA-2

Form of intimation of appointment of cost auditor by the company to MCA. Every company must file a notice of appointment of cost auditor with RoC through online in Form CRA-2 within 30 days of the board meeting in which the appointment is made or within 180 days from the date of commencement of the financial year.

Form CRA-3

Form of Cost Audit Report - This form CRA-3 provides a format in which the Cost auditor has to submit his cost audit report to Company. The cost audit report is a certificate containing five paragraphs on fifteen specific points such as

• Cost accounting system and cost accounting records
• Inventory valuation
• Budgetary control system
• Related party transactions
• Payments default to the Governments / Banks
• Actual exports, Export benefits, and incentives on their profitability
• Internal audit
• Suggestions concerning cost control and cost reduction
• Independent audit opinion regarding the cost accounting records

After the audit is duly complete, the auditor will submit the Form CRA-3 to the company. The Cost Audit Report in form CRA-3 must be submitted by the Cost Auditor to the Company within 180 days of closure of the financial year. The company must then furnish the cost audit report, with full details and explanations to MCA through Form CRA-4 along with the digital signature of the Cost Auditor.

Form for filing Cost Audit Report with the Govt. On the receipt of the Cost audit report from Cost auditors, the company need to submit the same to Central Government in form CRA-4 within 30 days from obtaining the audit report.

Fee for filing CRA – 4 (Cost Audit Report)

The fee for filing CRA – 4 (Cost Audit Report) is tabulated here for reference according to the Companies (Registration Offices and Fees) Rules, 2014

The fee for filing CRA -4 in case a company does not have share capital is Rs.200 per document and the foreign companies have to give Rs.6000 for filing.

Additional Fee (Penalty for Late Filing)

Note: As per the MCA notification dated 10.09.2020, the companies are exempted from the payment of an additional fee.

Documents Required

• XBRL document in respect of the cost audit report and company’s information and explanations on every qualification and reservation contained
• Any other information can be provided as an optional attachment

Procedure for Filing of eForm CRA-4

The following steps can be used for filing the eForm CRA-4 on the MCA portal.

• The applicant needs to access the official website of the Ministry of Corporate Affairs (MCA) to file eForm CRA-4. By login to the portal, the applicant can upload the e-form CRA-4.
• After login to the portal, provide the following details:
  • Corporate identity number (CIN) or foreign company registration number (FCRN) of the company
  • SRN of 23C/ CRA-2 filed for appointment of Cost Auditor
  • Specify the financial year for which the report is being filed
  • Date of the meeting of the Board of Directors in which Annexure to the cost audit report was approved
  • Number of Industries/ Service for which the Cost Audit Report is being submitted
  • Details of regulated sectors/ non-regulated sectors for which the Cost Audit Report is being submitted
  • Details of prescribed industries under-regulated sectors/non-regulated sectors for which Cost Audit Report is not applicable
  • Details of the cost auditor appointed including, the number of cost auditor, category of cost auditor, membership number, name, and Firm registration number (FRN)
  • Date of the board meeting in which cost auditor was appointed
  • Type of appointment of cost auditor
  • Describe the scope of an audit of the cost auditor, firm/LLP
  • Date of receipt of a copy of the cost audit report by the company
  • Provide the details of cost auditor’s repost
• Attach the DSC of the person digitally signing the form. The person digitally signing the form can be any one of the following:
  • Director
  • Manager
  • CEO
  • CFO
  • The company secretary of the company
  • Authorized representative
• By clicking on the attach button, the required document can be uploaded and click on the pay payment button for making a processing fee.
• On successful submission of the form CRA-4, the eForm will be processed by the Ministry of Corporate Affairs.

The format of the e-Form CRA-4 is attached here for reference:

SRN Generation

SRN will be generated and displayed to the applicant on the successful submission of the form CRA-4. This SRN will be used for future correspondence with MCA.

Challan Generation

On successful submission, a challan will be generated depicting the details of the fees paid by the company to the Ministry. It is the acknowledgement to the applicant that the form CRA-4 has been filed. When the form CRA-4 is completely processed by the authority, an acknowledgement will be sent to the official mail of the company.

Conclusion:

With the extension provided for filing Form CRA-4 until December 31, 2025, companies now have ample time to comply without incurring additional penalties. Ensuring timely submission of the Cost Audit Report will help maintain regulatory compliance and avoid any legal issues.

If you need assistance with Cost Audit filings or Form CRA-4 submission, IndiaFilings can help you navigate through the process. Contact us today to streamline your Cost Audit Report filing!

Get Started!