Understanding e-Form CRA-4: The Final Step in Cost Audit Compliance
CS Rantu Das
CS Rantu Das is the Founder and Managing Partner of M/s. Rantu Das & Associates, a firm established in 2010. As a Fellow Member of ICSI and a law graduate (LL.B., LL.M.), with an M.Com from Calcutta University, he has over 13 years of expertise in corporate laws, SEBI matters, FEMA, RBI regulations, and compliance audits. He regularly represents cases before NCLT and NCLAT under the Companies Act, 2013, and IBC, 2016.
Legal Foundation & Purpose
e-Form CRA-4 is a mandatory compliance form under Section 148(6) of the Companies Act, 2013, and Rule 6(6) of the Companies (Cost Records and Audit) Rules, 2014. When a cost auditor completes the cost audit for a company—typically within 180 days after the financial year-end, using Form CRA-3—the company is required to submit that report to the Central Government through e-Form CRA-4 within 30 days of receiving it.
The form serves to convey the cost audit report alongside detailed explanations regarding any qualifications, reservations, adverse remarks, observations, or suggestions made by the cost auditor. This ensures transparency and adherence to statutory audit standards.
Key Updates Effective July 14, 2025
Recent amendments under the Companies (Cost Records and Audit) Amendment Rules, 2025, have updated several disclosure requirements in e-Form CRA-4, effective from 14 July 2025. The key changes include:
1. Lead Auditor Status: Companies must now specify whether the cost auditor is acting as the lead auditor when multiple auditors are appointed.
2. AGM Extension Disclosure: If a company has extended its Annual General Meeting (AGM), the form must now include:
a. The Service Request Number (SRN) of Form GNL-1 is used to apply for the AGM extension.
b. The revised AGM date is approved following the extension.” (if describing a procedural requirement)
These updates strengthen regulatory oversight and better align reporting timelines with AGM schedules.
Step-by-Step Filing Guide
Here is the standard process for preparing and submitting e-Form CRA-4:
1. Access the MCA Portal
Log in to the Ministry of Corporate Affairs (MCA) e-filing portal, where the form is available for download and submission.
2. Fill Core Details
a. Corporate Identity Number (CIN) or Foreign Company Registration Number (FCRN).
b. Organization name, registered office address, and email (auto-populated after using the Pre-Fill option).
c. SRN of Form 23C or CRA-2 related to the cost auditor appointment.
d. Indicate if the financial year has changed and specify relevant dates.
e. Industry details, including the number and nature (regulated/non-regulated) of sectors, products, or services covered by the cost audit.
3. Auditor Information
a. Details of each cost auditor, including category, membership/firm registration number, and contact information.
b. Date of board meeting approving the appointment of the cost auditor.
c. Scope of the audit and the date on which the company received the audit report.
d. Whether the auditor’s report contains qualifications, adverse remarks, reservations, or suggestions, along with explanations if applicable.
4. Attachments & Declaration
a. Attach the cost audit report and any explanatory annexures in XBRL or PDF format.
b. Include board resolution details authorizing the filing.
c. Provide the Digital Signature Certificate (DSC) of an authorized signatory such as a Director, Chief Executive Officer (CEO), Chief Financial Officer (CFO), Manager, Company Secretary, or Authorized Representative.
5. Validation & Submission
a. Use the Check Form feature to validate mandatory fields and formatting.
b. Submit the form electronically. Upon successful submission, the system auto-approves the filing and sends an email confirmation of the status.
Fee Structure
The filing fee for e-Form CRA-4 depends on the company’s nominal share capital, as per the Companies (Registration Offices and Fees) Rules, 2014:
- Less than ₹1 lakh: ₹200 per document
- ₹1 lakh to ₹4.99 lakh: ₹300
- ₹5 lakh to ₹24.99 lakh: ₹400
- ₹25 lakh to ₹99.99 lakh: ₹500
- ₹1 crore or more: ₹600
- Companies without share capital: ₹200 flat
Penalties for Late Filing
Late submission of e-Form CRA-4 leads to higher fees, calculated by multiplying the normal fee by a fixed factor:
- Up to 30 days late: 2× normal fee
- 31–60 days: 4×
- 61–90 days: 6×
- 91–180 days: 10×
- More than 180 days: 12×
In past financial years, the MCA has occasionally extended filing deadlines and relaxed additional fees under special circumstances, such as during the COVID-19 pandemic. For example, for FY 2020–21, the deadline was extended to 30 November 2021 if the auditor submitted the report to the board by 31 October 2021.
Why e-Form CRA-4 Matters
Filing e-Form CRA-4 is not merely a statutory formality but a crucial component of corporate governance. It:
- Demonstrates adherence to cost audit requirements.
- Records and explains the auditor’s observations, ensuring greater transparency.
- Aligns audit completion with AGM timelines under the new amendments.
- Enables government authorities to maintain accurate regulatory records.
- Helps companies avoid steep penalties and legal complications.
In essence, timely and accurate submission of e-Form CRA-4 allows a company to maintain credibility, meet legal obligations, and reinforce good governance practices.
For any clarifications or queries, please feel free to reach out to us at admin@fintracadvisors.com
Disclaimer
The content published on this blog is for informational purposes only. The opinions expressed here are solely those of the respective authors and do not necessarily reflect the views of Fintrac Advisors. No warranties are made regarding this information’s completeness, reliability, or accuracy. Any actions taken based on the information presented in this blog are solely at the reader’s risk, and we will not be liable for any losses or damages resulting from its use. It is recommended that professional expertise be sought for such matters. External links on this blog may direct users to third-party sites beyond our control. We do not take responsibility for their nature, content, or availability.
