CRA-4: when must we file the cost audit report?

Your company is covered by cost audit. The cost auditor has finished, or is about to finish, the report. Now the practical question: by when must the company send that report to the Ministry of Corporate Affairs (MCA) in Form CRA-4?

The short answer is that the clock starts when the company receives a copy of the report, not at year-end and not at the Board's appointment of the auditor. This article sets out both clocks (the auditor's and the company's), a worked example, the portal steps, and what happens on default.

Who this applies to

Section 148 of the Companies Act, 2013 lets the Central Government order the audit of cost records for specified classes of companies. The Companies (Cost Records and Audit) Rules, 2014 apply to the companies covered under them. The rule says "every company covered under these rules" must furnish the report (rule 6(6), Cost Records and Audit Rules 2014). Whether you are covered depends on your category and thresholds in the Rules themselves, and on whether any exclusion applies. Check that first, or ask your CA. This article assumes the company is covered and has already appointed a cost auditor. For the appointment filing (Form CRA-2), see our separate CRA-2 article.

The two clocks

There are two separate periods. People mix them up.

Clock 1: the cost auditor's period. Every cost auditor must forward a duly signed report to the Board of Directors within one hundred and eighty days from the closure of the financial year to which the report relates (rule 6(5), Cost Records and Audit Rules 2014, as substituted by G.S.R. 695(E), 2016). The Board must then consider and examine the report, particularly any reservation or qualification in it (rule 6(5)).

The cost auditor reports in Form CRA-3 (rule 6(4), Cost Records and Audit Rules 2014).

Clock 2: the company's period. Every covered company must, within thirty days from the date of receipt of a copy of the cost audit report, furnish the Central Government with that report, along with full information and explanation on every reservation or qualification in it, in Form CRA-4 (rule 6(6), Cost Records and Audit Rules 2014). Section 148(6) of the Companies Act, 2013 says the same thing in the statute: thirty days from receipt of a copy of the report, with full information and explanation on every reservation or qualification.

So Clock 2 starts on receipt. Keep the proof of the date you received the report.

XBRL, not a PDF upload

Rule 6(6) requires Form CRA-4 in Extensible Business Reporting Language (XBRL) format, in the manner specified in the Companies (Filing of Documents and Forms in Extensible Business Reporting language) Rules, 2015, along with the fees specified in the Companies (Registration Offices and Fees) Rules, 2014 (rule 6(6), as substituted by G.S.R. 695(E), 2016).

The current form is the one substituted by G.S.R. 361(E) dated 30 May 2025, in force from 14 July 2025. It is filed pursuant to section 148(6) and rule 6(6). Among other things it asks for:

• the SRN of the Form CRA-2 (or old Form 23C) filed for the appointment of the cost auditor;
• the financial year covered, and whether the year has changed;
• the date of the Board meeting at which the annexure to the cost audit report was approved;
• whether an extension of the Annual General Meeting (AGM) was granted, with the SRN of the extension application and the revised AGM due date;
• whether the report has adverse remarks, observations or suggestions; and
• an XBRL document of the cost audit report, with every qualification and reservation and the company's explanations.

The form carries a declaration that the attached XBRL documents are the converted copies of the duly signed cost audit report and of the company's information and explanations under section 148(6). It is digitally signed by a Director, Manager, Company Secretary, CEO, CFO or an authorised representative, who must also be authorised by a Board resolution whose number and date the form asks for.

We did not find the CRA-4 fee amount on file. Check the current fee on the MCA portal before you file.

The AGM extension proviso

If the company has obtained an extension of time for holding its AGM under section 96(1) of the Companies Act, 2013, it may file CRA-4 within the resulting extended period for filing financial statements under section 137 (proviso to rule 6(6), inserted by G.S.R. 1157(E), 2018). The 2025 form has fields for this extension.

This proviso only helps a company that really obtained an AGM extension. Do not assume it applies. Check your own extension order and the extended period.

Worked example

Take a company with financial year 2026-27, which ends on 31 March 2027.

• Cost auditor's limit. One hundred and eighty days from closure of the year, counting 1 April 2027 as day one, ends on 27 September 2027. The cost auditor must forward the signed report to the Board by then (rule 6(5)).
• Company's limit. Suppose the company receives its copy of the report on 20 September 2027. Thirty days from receipt falls in the third week of October 2027. The exact date turns on whether the receipt day itself counts as day one. Counting it as day one gives 19 October 2027. Confirm the count convention with your CA, and file with room to spare.

If the Board gets the report only on the last allowed day, the company still has thirty days from receipt. But remember the Board must also examine every reservation or qualification and prepare explanations (rule 6(5)). Do that preparation early, so the thirty days are used for filing and not for drafting.

Step by step

• Record the receipt date. Keep a dated acknowledgement of when the company received a copy of the cost audit report. It starts the thirty-day clock (rule 6(6)).
• Check the cost statements. The cost statements and other statements annexed to the cost audit report must be approved by the Board before they are signed on behalf of the Board and submitted to the cost auditor (rule 6(3B), Cost Records and Audit Rules 2014, inserted by G.S.R. 695(E), 2016). The CRA-4 form asks for the Board meeting date at which the annexure was approved.
• Table the report at the Board. The Board considers and examines the report, particularly any reservation or qualification (rule 6(5)).
• Write the explanations. For each reservation or qualification, prepare full information and explanation (section 148(6), Companies Act 2013; rule 6(6)). Match each explanation to the item it answers.
• Prepare the XBRL document. Convert the signed report and explanations as the XBRL Rules require (rule 6(6)).
• Get the Board authorisation for the signatory. The form asks for the resolution number and date.
• File CRA-4 on the MCA portal, digitally signed. Quote the SRN of the CRA-2 filed for the appointment.
• Pay the fee. See the fee note above; check the MCA portal.
• Keep the SRN and the filed documents with the statutory records.

What not to do

• Do not count the thirty days from year-end or from the appointment. The statute and the rule both say "from the date of receipt of a copy of the cost audit report" (section 148(6); rule 6(6)).
• Do not file the report bare. Every reservation or qualification needs full information and explanation (section 148(6)).
• Do not rely on old extension circulars. The MCA has issued year-specific relaxations in the past, for example for particular financial years. They were relief for those years only. Check whether any relief applies to your year on the MCA portal.
• Do not skip the Board. The rule says the Board shall consider and examine the report (rule 6(5)).
• Do not make a false statement on the form. The form warns that false statements are punishable.

What happens if you are late

Section 148(8) of the Companies Act, 2013 says that if any default is made in complying with section 148, the company and every officer of the company who is in default are punishable as provided in section 147(1). Section 147(1) provides a fine on the company of not less than twenty-five thousand rupees, which may extend to five lakh rupees, and a fine on every officer in default of not less than ten thousand rupees, which may extend to one lakh rupees (section 148(8) and section 147(1), Companies Act 2013). A defaulting cost auditor is punishable as provided in section 147(2) to (4) (section 148(8)(b)).

We did not find on file a separate additional filing fee for a late CRA-4 under current rules. Check the MCA portal for any additional fee before you file late.

What to do now

• Next step: Record the date the company received the cost audit report, and start the explanations for every reservation or qualification (section 148(6), Companies Act 2013).
• Deadline: File CRA-4 in XBRL within thirty days from the date of receipt of a copy of the report, or within the extended period if the AGM extension proviso applies (rule 6(6) and its proviso, Cost Records and Audit Rules 2014).
• Consequence of missing it: Default under section 148(8), with a fine on the company of twenty-five thousand rupees to five lakh rupees and on each officer in default of ten thousand rupees to one lakh rupees (section 147(1), Companies Act 2013).

Have a CA review your facts before you act or file.

FAQs

Is the CRA-4 deadline 30 days from year-end?
No. It is thirty days from the date of receipt of a copy of the cost audit report (rule 6(6), Cost Records and Audit Rules 2014; section 148(6), Companies Act 2013). The cost auditor has up to one hundred and eighty days from the closure of the financial year to forward the report to the Board (rule 6(5)).

Who files CRA-4, the cost auditor or the company?
The company. Rule 6(6) says every company covered under the Rules shall furnish the report to the Central Government. The cost auditor submits the report to the Board in Form CRA-3 (rule 6(4)).

Do we have to file in XBRL?
Yes. Rule 6(6) requires Form CRA-4 in XBRL format, in the manner specified in the Companies (Filing of Documents and Forms in Extensible Business Reporting language) Rules, 2015.

We got an AGM extension. Does the CRA-4 date move?
It can. The proviso to rule 6(6) allows a company that obtained an AGM extension under section 96(1) to file CRA-4 within the resulting extended period for financial statements under section 137. Check your own extension and the extended period first.

What if the cost auditor's report has adverse remarks?
The company must furnish full information and explanation on every reservation or qualification along with the report (section 148(6), Companies Act 2013). Prepare these before the thirty days run out.

Does the Board have to look at the report first?
Yes. The Board shall consider and examine the report, particularly any reservation or qualification in it (rule 6(5), Cost Records and Audit Rules 2014).

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See Also

• CRA-2: when must we file the cost auditor's appointment?
• Cost records and cost audit under section 148: the second audit companies overlook
• Finance Act 2026: changes that touch a private company's directors