Companies (Auditor’s Report) Order, 2020 (CARO 2020)
Background
Section 143(11) of the Companies Act, 2013 requires that the Auditor’s report of specified class of companies should include a statement on the prescribed matters. These reporting requirements have been prescribed under the Companies (Auditor’s Report) Order (hereafter referred as CARO), 2015 issued by the Ministry of Corporate Affairs (MCA) on 10th April, 2015. Thereafter on the basis of recommendation of Committee set up by MCA, CARO, 2016 had been issued on 9th February 2016.To curb corporate fraud & scams, the MCA has now issued CARO,2020 on 25th February 2020.
The new CARO has aim to
improve quality of reporting by Auditors
minimize financial wheeling
bring greater transparency in the financial statement of eligible companies
ensure corporate governance
Key Points of CARO, 2020
The CARO, 2020 is applicable for audit of financial statements of eligible companies for the financial years commencing on or after the 1st April, 2019.
There are no changes in the applicability of CARO, 2020.
There are in total 21 clauses as compared to 16 clauses in CARO 2016, 7 clauses inserted, 1 clause merged with other and 1 clause deleted.
CARO, 2016 is not applicable to Consolidate Financial Statements (CFS). But now in CARO, 2020 comprise a clause which is now applicable to report on CFS.
Requirements that have been carried forward with certain modification
Clause No | Clause Name | CARO,2016 | Changes in CARO, 2020 |
1 | Non –current assets |
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2 | Inventory and other current assets |
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3 | Investments, loans or advances by company |
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8 | Loans or other borrowings |
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9 | Money raised by IPOs, FPOs |
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10 | Fraud |
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12 | Nidhi Company |
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16 | NBFC |
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New Requirement under CARO, 2020
Clause No | Clause Name | Changes in CARO, 2020 |
8 | Disclosure of undisclosed transactions |
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14 | Internal Audit System |
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17 | Cash losses |
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18 | Consideration of outgoing auditor |
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19 | Material uncertainty in relation to realisation of financial assets and payment of financial liabilities |
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20 | Compliance of CSR |
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21 | Qualifications or adverse remarks in the consolidated financial statements |
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FAQ on CARO, 2020
What is effective date of CARO,2020 ?
Ans. The CARO, 2020 will be applicable from the financial year beginning from 1st April, 2019.
Is there any change in applicability on eligible companies of CARO, 2020 as compared to CARO,2016 ?
Ans. No, there is no change in applicability on eligible companies of CARO, 2020.
How many new clause have been added in CARO, 2020?
Ans. In CARO, 2020, 7 new clause has been inserted. The CARO, 2020 includes certain additional clauses, as compared to CARO, 2016, and the existing clauses of CARO, 2016 have been re-drafted to elicit detailed comments from the auditors.
How many clauses are now in CARO?
Ans. The new CARO contains total 21 clause whereas CARO, 2016 having only 16 clause.
Is any clause has been deleted?
Ans. Yes, one clause relating to preferential allotment or private placement has been merged with another clause of IPO, FPO.
Which companies are exempt from the applicability of CARO?
Ans. CARO is not applicable to the following companies-
1. Banking Companies
2. Insurance Companies
3. Section 8 Company
4. One Person Company
5. Small Company
6. Select Class of Private Company
Which are the select class of private companies to which CARO is not applicable?
Ans. CARO is not applicable to private companies which satisfied all the following conditions –
Paid up share capital & reserve and Surplus not more than 1 crore rupees
Total borrowing from bank or financial institution is not more than 1 crore at any time during the financial year
Total Revenue(As per Schedule III) does not exceed 10 crore rupees
Has ICAI issued any guidance on reporting under CARO, 2020?
Ans. No, as the CARO,2020 is recently introduced. The ICAI will soon issue Guidance Notes as issued previously on CARO, 2016.
Is CARO will apply on branch auditor?
Ans. The Order is also applicable to the audits of branch(es) of a company since sub-section 8 of section 143 of the Act read with Rule 12 of the Companies (Audit and Auditors) Rules, 2014 clearly specifies that a branch auditor has the same duties in respect of audit as the company’s auditor. It is, therefore, necessary that the report submitted by the branch auditor contains a statement on all the matters specified in the Order, as applicable to the company.
Is CARO, 2020 require any report on Consolidated Financial Statements (CFS)? Ans. CARO 2020 comprises a clause which is now applicable to auditor’s report on CFS. According to this clause, where any qualifications or adverse remarks are highlighted by the auditors in their respective standalone companies’ CARO reports, then the details of such remarks are to be mentioned by the auditor of the company in his CARO report of CFS.
For Full text of CARO, 2020 please refer: http://www.mca.gov.in/Ministry/pdf/Orders_25022020.pdf
Shashank Tamboli