Form ADT-1 for Appointment of Auditor: Due Date, Filing & Late Fees

After the conclusion of the Annual General Meeting (AGM), every company is required to inform the Registrar of Companies (ROC) about the appointment of an auditor or any change in the existing auditor. This intimation is done through Form ADT-1.

Submitting this form is a key annual compliance requirement under the Companies Act, 2013. It ensures that the ROC is officially notified whenever an auditor is appointed or replaced. This guide outlines the relevance of Form ADT-1, its filing requirements, and important compliance aspects to help companies avoid penalties and remain audit-compliant.

What is Form ADT-1?

Form ADT-1 is a statutory form filed with the Registrar of Companies to report the appointment of a company’s auditor. It must be submitted within 15 days from the date of appointment to comply with the Companies Act, 2013.

As per the Companies (Audit and Auditors) Amendment Rules, 2025, effective from 14 July 2025, filing Form ADT-1 has become mandatory for all first auditor appointments, including those made by the Board of Directors.

The form captures details such as the auditor’s name, their consent, and company particulars. Filing within the prescribed timeline is crucial, as any delay may lead to penalties. In accordance with Section 139(1) of the Companies Act, 2013, companies must file Form ADT-1 every year after the AGM in which the auditor is appointed, ensuring statutory compliance and financial transparency.

Purpose of Appointing an Auditor

An auditor examines the company’s financial records, verifies compliance with applicable laws, and presents a true and fair view of the company’s financial position to the management. This independent assessment helps maintain financial discipline and protects the interests of shareholders by offering an unbiased opinion on the company’s accounts.

Procedure for Appointment of an Auditor

The process of appointing an auditor is an essential compliance requirement that supports transparency, legal adherence, and shareholder protection.

Type of Auditor	Appointing Authority	Time Limit	Tenure
First Auditor	Board of Directors (or Members through EGM)	Within 30 days of incorporation (Board) / 90 days (Members)	Holds office till the conclusion of the first AGM; Form ADT-1 filing optional
Government Company Auditor	Comptroller & Auditor-General of India (or Board if not appointed)	Within 60 days (CAG) / next 30 days (Board)	Holds office till the conclusion of the first AGM
Subsequent Auditor	Members of the company	After AGM	Holds office till the conclusion of the 6th AGM from the date of appointment

Key Points on Appointment of Auditor

• The first auditor is appointed by the Board of Directors or, if required, by the members, whereas all later appointments are made solely by the company’s members.
• Only a practising Chartered Accountant is eligible to be appointed as an auditor.
• Prior to appointment, written consent along with a certificate of compliance under Section 141 of the Companies Act, 2013 is compulsory.
• The auditor’s appointment must be reported to the Registrar of Companies within 15 days through Form ADT-1.
• For statutory compliance and transparency, the auditor’s appointment should be ratified at every AGM.

Appointing an auditor is a vital annual compliance requirement for companies. For a detailed understanding, refer to our blog: Audit – An Imperative Process for Company Annual Compliance.

Who Needs to File Form ADT-1?

The obligation to file Form ADT-1 lies with the company, not the auditor. Every company that appoints or reappoints an auditor must submit this form to the Registrar of Companies (RoC) within the specified timeframe.

Entities Required to File Form ADT-1

All Categories of Companies

• Listed and unlisted companies
• Public and private limited companies
• One Person Companies (OPCs) and other registered entities

Newly Incorporated Companies

• Companies must file Form ADT-1 after appointing their first auditor, whether appointed by the Board of Directors or by the members.

Companies Filling a Casual Vacancy

• If an auditor is appointed due to resignation, death, disqualification, or any other reason, Form ADT-1 must be filed to notify the new appointment.

Companies Appointing or Reappointing Auditors at AGM

• Any appointment or reappointment of an auditor at the AGM requires filing Form ADT-1 within 15 days of passing the resolution.

Note: Since audit is mandatory for all companies, Form ADT-1 filing is required in every applicable case, including casual vacancies. Filing ADT-1 formally confirms to authorities that the auditor has been validly appointed to conduct the audit.

Form ADT-1: Filing Due Dates and Timelines

For Newly Incorporated Companies

• Form ADT-1 must be filed within 15 days of the first board meeting.
• The first board meeting must be held within 30 days of incorporation, where auditor appointment is included in the agenda.
• This effectively provides a total window of 45 days from incorporation to file the first ADT-1.

Example: If a company is incorporated on 30 August 2025 and its first board meeting is held on 3 September 2025, the ADT-1 filing due date will be 18 October 2025.

For Existing Companies

• Form ADT-1 must be filed within 15 days of the AGM in which the auditor is appointed or reappointed.

Example: If the AGM is conducted on 30 September 2025, the ADT-1 filing deadline will be 14 October 2025.

Documents Required to File Form ADT-1

The following attachments are required while filing Form ADT-1 with the Registrar of Companies:

• Board Resolution or AGM Resolution: Copy of the resolution approving the auditor’s appointment.
• Auditor’s Written Consent: Written confirmation from the auditor accepting the appointment.
• Auditor’s Certificate: Declaration stating that the auditor is eligible and not disqualified under Section 141 of the Companies Act, 2013.
• Intimation to Auditor: Copy of the communication sent by the company informing the auditor of their appointment.

These documents validate the auditor’s appointment and ensure full compliance with the Companies Act, 2013.

How to File Form ADT-1

Form ADT-1 is an electronic form that companies must submit through the Ministry of Corporate Affairs (MCA) portal.

Step 1: Download the Form
Visit the MCA website and download Form ADT-1 from the company forms section.

Step 2: Enter Required Details
Fill in the necessary information, including:

• Corporate Identification Number (CIN) of the company
• Nature of the auditor’s appointment and the audit period
• Auditor’s PAN and address (or details of the audit firm)
• Auditor’s membership number (or firm registration number)

Note: By clicking the ‘Pre-fill’ option in Section 1, most company details are filled automatically. Any field can be edited manually, if needed.

Step 3: Attach Supporting Documents
Upload scanned copies of the required attachments such as the board/AGM resolution, auditor’s consent, auditor’s certificate, and intimation sent to the auditor.

Step 4: Digital Signature
The form must be digitally signed by an authorized director using a valid Digital Signature Certificate (DSC).

Step 5: Verify the Form
Use the ‘Check Form’ button to detect any missing details or errors.
If issues are highlighted, click ‘Modify’, correct the information, and recheck the form until it is error-free.

Step 6: Pre-Scrutiny
Click on ‘Pre-Scrutiny’ to validate the information entered. Ensure the form passes this step without errors.

Step 7: Submit the Form
After successful verification, submit the form. Form ADT-1 is auto-approved by the MCA.
A confirmation email is sent to the company’s registered email address upon successful submission.

Filing Fees for MCA Form ADT-1

The fee payable for filing Form ADT-1 with the Registrar of Companies depends on the company’s nominal share capital:

Sl. No.	Nominal Share Capital	Fees (₹)
1	Below ₹1,00,000	200
2	₹1,00,000 – ₹4,99,999	300
3	₹5,00,000 – ₹24,99,999	400
4	₹25,00,000 – ₹99,99,999	500
5	₹1,00,00,000 and above	600

Penalties for Non-Filing or Delayed Filing of Form ADT-1

Failure to file Form ADT-1 on time attracts substantial penalties.

Sl. No.	Delay (Days)	Penalty
1	Up to 15 days	1× normal fee
2	16–30 days	2× normal fee
3	31–60 days	4× normal fee
4	61–90 days	6× normal fee
5	91–180 days	10× normal fee
6	More than 180 days	12× normal fee

Filing Form ADT-1 is a compulsory compliance obligation, and companies should ensure timely submission to avoid significant financial penalties.

Key Takeaways

• Companies with share capital below ₹1,00,000 are required to pay a filing fee of ₹200, which increases with higher share capital.
• Delayed filing leads to multiple times the normal fee, with penalties rising up to 12 times for delays exceeding 180 days.

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Final Thoughts: Filing Form ADT-1 Is Compulsory

Submitting Form ADT-1 is a statutory requirement for all companies whenever an auditor is appointed or reappointed, including appointments made to fill casual vacancies. Although filing for the first auditor is not strictly mandatory, it is advisable as a good compliance practice. The form must be filed within 15 days from the date of appointment, and the entire responsibility rests with the company, not the auditor.

At KMG CO LLP, we streamline annual compliance for businesses by ensuring accurate and timely filing of Form ADT-1, helping companies remain compliant without unnecessary complexity.

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