CRA-2: when must we file the cost auditor's appointment?

Your company is covered by cost audit. The Board has chosen a cost accountant, or is about to. Now someone asks the practical question: by what date must Form CRA-2 reach the Ministry of Corporate Affairs (MCA)? The answer is a two-limb test, and the shorter limb wins. Miss it and the company is in default under the Companies Act, 2013.

This article gives the clock, a worked example, the steps on the portal, and what to avoid. It covers only the appointment intimation (CRA-2). The cost audit report filing (CRA-4) has its own clock and is a separate topic.

Who this applies to

Cost audit applies to the companies in the categories listed in rule 3 and above the turnover thresholds in rule 4 of the Companies (Cost Records and Audit) Rules, 2014. Those companies must appoint a cost auditor (rule 6(1), Cost Records and Audit Rules 2014). The legal base is section 148, Companies Act 2013, under which the Central Government may order the audit of cost records for specified classes of companies.

A company that falls in rule 3 is still outside cost audit if its revenue from exports, in foreign exchange, exceeds seventy five per cent of its total revenue, if it operates from a special economic zone, or if it generates electricity for captive consumption through a captive generating plant (rule 4(3), Cost Records and Audit Rules 2014).

Check your category, thresholds and these exclusions from the Rules themselves, or with your CA, before assuming you are in or out. This article assumes you are in.

What the law says about who appoints

The cost auditor is a cost accountant appointed by the Board. The remuneration is determined by the members, in the manner prescribed (section 148(3), Companies Act 2013). So the Board appoints; the shareholders fix the fee.

Two guard rails sit in the same section:

A person appointed as the company's financial statutory auditor under section 139 cannot be appointed for the cost audit (first proviso to section 148(3), Companies Act 2013).
The cost auditor must comply with the cost auditing standards (second proviso to section 148(3), Companies Act 2013).

The deadline clock

Rule 6(1) sets the outer limit for appointment: the company must appoint a cost auditor within one hundred and eighty days of the commencement of every financial year (rule 6(1), Cost Records and Audit Rules 2014).

Rule 6(2) then sets the filing clock. The company must inform the cost auditor of the appointment, and file a notice with the Central Government in Form CRA-2 through electronic mode, along with the fee specified in the Companies (Registration Offices and Fees) Rules, 2014. The time limit is:

within thirty days of the Board meeting in which the appointment is made, or
within one hundred and eighty days of the commencement of the financial year,

whichever is earlier (rule 6(2), Cost Records and Audit Rules 2014).

Read it as: take the 30-day date, take the 180-day date, and file by whichever comes first.

We checked whether any later amendment changed this wording. The Rules have been amended by notifications of 2014, 2015, 2016, 2017, 2018, 2019 and 2025. The 2016 amendment (G.S.R. 695(E)) added a consent requirement and some provisos to rule 6. The 2025 amendment (G.S.R. 361(E)) replaced the forms. Of these we have read the 2016, 2018 and 2025 notifications and the principal Rules; none of them changes the "earlier of 30 days or 180 days" test in rule 6(2).

Worked examples

For a company whose financial year starts on 1 April 2026 (financial year 2026-27), the 180-day limit counted with 1 April as day one ends on 27 September 2026. The counting convention matters, so confirm the count with your CA. Here are two cases.

Case 1: Board appoints early. The Board meets on 10 June 2026 and appoints the cost auditor. Thirty days from the meeting is in July. That is earlier than the 180-day limit, so the July date is your deadline.

Case 2: Board appoints late. The Board meets on 10 September 2026. Thirty days from the meeting falls in October. The 180-day limit from the start of the year ends on 27 September 2026, which is earlier. So CRA-2 is due by 27 September 2026, only 17 days after the meeting. A Board that waits beyond that date has also missed the 180-day limit for making the appointment itself (rule 6(1)).

The lesson from Case 2: the later the Board meets, the less of the 30 days you get. Once you are past about 150 days into the year, the 180-day date, not the meeting date, controls. Put the appointment on the Board agenda early in the year so the 30-day limb is the binding one.

Other situations that trigger a CRA-2

CRA-2 is not only an annual filing. It also covers these:

Change of cost auditor. The cost auditor may be removed before the end of the term by a Board resolution, after a reasonable opportunity of being heard and with the reasons recorded in writing. The CRA-2 filed to intimate the appointment of another cost auditor must enclose the relevant Board resolution (provisos to rule 6(3), Cost Records and Audit Rules 2014). The cost auditor's own right to resign is not affected (third proviso to rule 6(3)).
Casual vacancy. A vacancy in the office of cost auditor caused by resignation, death or removal is dealt with by rule 6(3A), and the current CRA-2 is expressly filed under that sub-rule as well (form substituted by G.S.R. 361(E), 2025). The Board must fill the vacancy within a short window and the company intimates the Central Government in CRA-2. We have the exact day-limits of rule 6(3A) only from a consolidated text of the Rules, not from an amending notification, so read rule 6(3A) as currently notified, or ask your CA, before relying on the number of days.
More than one product or cost auditor. A single CRA-2 is filed giving the details of the sectors covered by cost audit and of the cost auditor. If the company appoints several cost auditors, only one CRA-2 is needed; the form has room for multiple auditors (ICMAI clarification, FAQ 1.13 on the Rules).

The term of the cost auditor runs until one hundred and eighty days after the closure of the financial year, or until the cost audit report is submitted for that year, whichever of the two applies (rule 6(3), Cost Records and Audit Rules 2014).

Step by step

Check that the company is covered. Confirm the rule 3 category, the rule 4 thresholds and the rule 4(3) exclusions.
Shortlist a cost accountant. Remember: not the company's section 139 statutory auditor (section 148(3), Companies Act 2013).
Get written consent and the certificate before appointing. Before the appointment is made, the company must obtain the cost auditor's written consent and a certificate under rule 6(1A) (proviso to rule 6(1), Cost Records and Audit Rules 2014). The certificate says, among other things, that the individual or firm is eligible and not disqualified under the Companies Act, the Cost and Works Accountants Act, 1959 and the rules made under them. It also says the criteria in section 141 are met so far as applicable, that the appointment is within the limits laid down under the Act, and that the list of pending professional conduct proceedings disclosed is true and correct (rule 6(1A), Cost Records and Audit Rules 2014).
Hold the Board meeting and pass the resolution. The Board appoints the cost auditor (section 148(3), Companies Act 2013). Record the date; the form asks for it.
Place the remuneration before the members. The members determine it in the prescribed manner (section 148(3), Companies Act 2013). Take the manner from the Rules or your CA.
Tell the cost auditor. Rule 6(2) requires the company to inform the cost auditor of the appointment (rule 6(2), Cost Records and Audit Rules 2014).
File CRA-2 on the MCA portal, digitally signed. The form in force 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(3) and rule 6(1), 6(2) and 6(3A). It asks for the date of the Board meeting at which the cost auditor was appointed, the scope of the audit, whether written consent and the rule 6(1A) certificate were obtained, and whether the cost auditor has changed from the previous year. A copy of the Board resolution is a mandatory attachment. In a filing that revises an earlier one, the form asks for the SRN of the original CRA-2 (or old Form 23C) filed for the same year.
Pay the fee. The fee is the one specified in the Companies (Registration Offices and Fees) Rules, 2014 (rule 6(2), Cost Records and Audit Rules 2014). We did not find the CRA-2 fee amount in the fee schedule we have on file, so check the current figure on the MCA portal before you file.
Keep the SRN and the approved Board resolution with your statutory records. You will need the SRN when filing CRA-4 later, as that form asks for the SRN of the CRA-2 filed for the appointment.

Who signs the form: it is digitally signed by a Director, Manager, Company Secretary, CEO, CFO or an authorised representative, with the company's Board authorisation (declaration in Form CRA-2 as substituted by G.S.R. 361(E), 2025).

What not to do

Do not file CRA-2 on the day you think you are "in time" without counting. The 180-day limb is counted from the first day of the financial year, not from the Board meeting.
Do not appoint the statutory auditor as cost auditor. Section 148(3), Companies Act 2013 bars it.
Do not appoint before you have consent and the certificate. The rule requires both before the appointment is made (proviso to rule 6(1)).
Do not forget that a change of cost auditor needs a fresh CRA-2 with the Board resolution enclosed (provisos to rule 6(3)).
Do not make a false statement on the form. The form itself warns that sections 448 and 449 of the Companies Act, 2013 punish false statements and false evidence.

What happens if you are late

Section 148(8) deals with default. If any default is made in complying with section 148, the company and every officer in default are punishable in the manner 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).

We have not found a separate late-filing additional fee for CRA-2 in the documents on file. Whether the MCA portal charges one on a delayed CRA-2 is something to check on the portal before you file late.

What to do now

Next step: Confirm the company is covered, then get the cost auditor's written consent and rule 6(1A) certificate, and put the appointment on the Board agenda (rule 6(1) and proviso, Cost Records and Audit Rules 2014).
Deadline: File CRA-2 within thirty days of the Board meeting or within one hundred and eighty days of the start of the financial year, whichever is earlier (rule 6(2), Cost Records and Audit Rules 2014).
Consequence of missing it: Default under section 148(8), with fines 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-2 deadline 30 days or 180 days?
Both are in the rule, and the earlier one applies. The filing is due within thirty days of the Board meeting making the appointment or within one hundred and eighty days of the commencement of the financial year, whichever is earlier (rule 6(2), Cost Records and Audit Rules 2014).

What is the last date to appoint the cost auditor?
The company must appoint within one hundred and eighty days of the commencement of every financial year (rule 6(1), Cost Records and Audit Rules 2014). For a year starting on 1 April, counting 1 April as day one, that is 27 September. Confirm the count with your CA.

Do we file CRA-2 every year?
The rule applies to the appointment for each financial year, because the obligation to appoint arises for every financial year (rule 6(1), Cost Records and Audit Rules 2014). Treat the intimation as an annual task unless your CA advises otherwise on the facts.

Can our statutory auditor also be the cost auditor?
No. A person appointed under section 139 as an auditor of the company cannot be appointed for conducting the audit of cost records (first proviso to section 148(3), Companies Act 2013).

What if the cost auditor resigns or is replaced during the year?
For a vacancy from resignation, death or removal, rule 6(3A) requires the Board to fill it and the company to intimate the Central Government in CRA-2; confirm the day-limits in the rule as currently notified before relying on them (rule 6(3A), Cost Records and Audit Rules 2014). Where another cost auditor replaces the first, the CRA-2 must enclose the relevant Board resolution (provisos to rule 6(3)).

Do we need one CRA-2 per product?
No. One CRA-2 is filed for the company, covering the sectors under cost audit, and one form is enough even where several cost auditors are appointed (ICMAI clarification, FAQ 1.13 on the Rules).

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