Summary: Companies covered by cost audit for FY 2025-26 should not treat CRA-4 as having one common calendar due date. The Companies Act, 2013 and the Companies (Cost Records and Audit) Rules, 2014 create two linked clocks: the cost auditor submits the report to the Board within 180 days from financial-year closure, and the company files CRA-4 with the Central Government within 30 days from receiving that report. This guide explains how to evidence the actual receipt date, reconcile the signed report and XBRL instance, address qualifications through the Board, use the form introduced from 14 July 2025, and prevent common validation or responsibility gaps.
- The CRA 4 clock starts with receipt of the cost audit report
- A late September auditor deadline does not create one filing date for every company
- Use the CRA 4 form applicable from 14 July 2025
- Reconcile the signed report with the XBRL filing package
- Board papers should answer each cost audit finding
- A controlled filing sequence for FY 2025 26
- Frequently Asked Questions on CRA 4 for FY 2025 26
- 1 Is 27 October 2026 the CRA 4 due date for every 31 March company
- 2 Does an emailed draft start the thirty day period
- 3 Can the company file before the Board examines the qualifications
- 4 Which CRA 4 version applies to an October 2026 filing
- 5 Does successful MCA validation prove that the report is correct
- 6 What should be retained after filing CRA 4
- Key Takeaways
The CRA 4 clock starts with receipt of the cost audit report
Section 148(6) of the Companies Act, 2013 requires a company to furnish the cost audit report to the Central Government within thirty days from the date it receives a copy of the report. The filing must include the company’s information and explanation on every reservation or qualification in the report. Rule 6(6) of the Companies (Cost Records and Audit) Rules, 2014 operationalises that obligation through Form CRA-4 in the prescribed manner and with the prescribed fee. The controlling event is therefore the company’s receipt of the report, not 30 September, the annual general meeting date, the financial-statement filing date or a date copied from another company’s calendar.
For a company whose financial year closed on 31 March 2026, rule 6(5) separately requires the cost auditor to forward the duly signed report and annexures to the Board of Directors within 180 days from closure of the financial year. That outer limit ordinarily brings the auditor-side action into late September 2026. It does not, by itself, prove the company’s CRA-4 deadline. A company that received the signed report earlier has an earlier 30-day filing window; a company that records a different receipt date must be able to support it with reliable evidence and must examine whether the auditor complied with rule 6(5).
| Compliance event | Responsible person | Statutory timing | Evidence to retain |
|---|---|---|---|
| Cost audit is completed and report is signed | Cost auditor | Within 180 days from financial-year closure under rule 6(5) | Signed report, annexures, UDIN or professional authentication records where applicable, transmission record |
| Report is received and placed before the Board | Company and Board | Receipt date starts the separate CRA-4 clock | Dated email or portal delivery, inward record, agenda papers and Board minutes |
| Reservations or qualifications are answered | Board and management | Before CRA-4 is approved and filed | Point-wise explanation linked to report paragraphs and supporting records |
| CRA-4 and XBRL documents are submitted | Company and authorised signatory | Within 30 days from actual receipt under section 148(6) | Filed form, attachments, payment receipt, SRN and acknowledgement |
A late September auditor deadline does not create one filing date for every company
The distinction matters in October 2026 because many FY 2025-26 reports may have been finalised near the 180-day outer limit. If, only as an illustration, the company received the complete signed report on 27 September 2026, a thirty-day calendar calculation would ordinarily point to 27 October 2026. That is not a universal CRA-4 due date. The company should calculate its own period from the documented receipt event, apply the statutory rules for computing time, check whether the last day is affected by an MCA portal or government extension, and preserve the basis used. An unsigned draft, an incomplete annexure set or a file circulated only for discussion should not casually be labelled the statutory receipt without examining the facts.
The Board process must also be real rather than retrospective. Rule 6(5) states that the Board should consider and examine the report, particularly reservations or qualifications. Section 148(6) then requires the company’s information and explanation to accompany the filing. Minutes should show that directors considered the findings and management’s response. A generic sentence stating that the report was noted is weak evidence where the cost auditor has identified material quantity, cost allocation, related-party, reconciliation or record-maintenance issues.
Use the CRA 4 form applicable from 14 July 2025
The Companies (Cost Records and Audit) Amendment Rules, 2025 substituted Form CRA-4 with effect from 14 July 2025. A FY 2025-26 filing made in October 2026 must therefore use the current MCA V3 form and current utilities, not a locally saved legacy form or an old instruction kit. The 2025 form structure requires company particulars, the period of the cost audit, details of the cost auditor, information concerning the report and Board consideration, and disclosures tied to the filing. The filer should read the live form and instruction kit immediately before upload because portal validations and utility versions can change even where the underlying statutory period does not.
CRA-4 is not a substitute for the cost audit report. The company files the prescribed form together with the report and the required documents in the prescribed XBRL-based process. Names, membership and firm-registration details, financial-year dates, product or service coverage and the Board meeting date should reconcile across CRA-2, the engagement records, the signed report, the XBRL instance and CRA-4. If an earlier CRA-2 was revised or multiple cost auditors were appointed for different products or locations, the mapping should be tested before the filing package is generated.
Reconcile the signed report with the XBRL filing package
A technically valid XBRL file can still be substantively wrong. The reporting team should begin with the final signed cost audit report and annexures, not with last year’s XBRL instance. Confirm the exact reporting period, units of measurement, product and service codes, plant or location coverage, related-party disclosures, capacity and production information, cost statements, reconciliation to financial accounts and every auditor observation. Opening balances and prior-year comparatives should agree with the approved source records or be explained. Copy-forward should be controlled field by field because a taxonomy element can accept a value that belongs to a different period or category.
The company should also compare the XBRL rendering with the human-readable signed report. Every qualification, emphasis, reservation and adverse observation must remain visible and correctly tagged. The Board’s explanation should respond to the same issue rather than changing its scope. Where management disagrees with an auditor’s conclusion, CRA-4 is not the place to erase the conclusion; the filing should faithfully carry the report and state the company’s reasoned response. Any revised report must be handled through a documented professional and corporate process, not by editing an attachment after signature.
| Reconciliation point | Primary comparison | Failure signal |
|---|---|---|
| Reporting identity | CIN, legal name, registered office and financial year | Entity or period differs between CRA-2, report and form |
| Auditor identity | Individual or firm name, membership and registration particulars | Expired copy-forward data or wrong signing partner |
| Scope | Products, services, locations and regulated activity covered | XBRL omits a covered unit or includes an out-of-scope activity |
| Financial reconciliation | Cost statements and reconciliation to audited financial accounts | Unexplained gap, inconsistent unit or transposed figure |
| Qualifications | Signed report, XBRL tags and Board explanation | Qualification is shortened, omitted or answered generically |
Board papers should answer each cost audit finding
Before authorising the filing, the Board or the properly convened decision-making process should have a point-wise note. Each note should identify the auditor’s paragraph, the underlying record or control, management’s factual position, corrective action already taken, the owner of any open action and a realistic completion date. This structure distinguishes an explanation from a promise. If the issue affects financial reporting, inventory valuation, transfer pricing, regulated pricing, GST classification or another statutory return, the company should involve the relevant finance, tax and legal teams and record whether a consequential correction is required.
Directors should also be told what CRA-4 does not establish. Acceptance of the form by the MCA portal does not certify the accuracy of the cost records, approve the company’s explanations or remove liability for a false statement. The professional certification and authorised-signatory declarations must be based on reviewed records. If a pre-scrutiny or upload error is cured, the company should keep the error log and the final validated package so that the audit trail shows what changed and why.
A controlled filing sequence for FY 2025 26
1. Record the date and method by which the complete signed cost audit report and annexures were received; calculate the 30-day period from that event and obtain a legal view if receipt is disputed.
2. Confirm that the company and the covered products or services fall within the applicable cost-record and cost-audit framework for FY 2025-26; do not assume that last year’s coverage is unchanged.
3. Reconcile the cost auditor’s appointment details and CRA-2 history with the signing auditor, reporting period and scope shown in the report.
4. Prepare a point-wise management response to every reservation or qualification and place the final report and response before the Board for examination.
5. Generate the current XBRL instance from the final source records, run the current MCA validation tool and compare the rendered output with the signed report.
6. Complete the current V3 CRA-4, attach the correct final files, obtain professional certification and authorised-signatory approval only after a documented review.
7. File within the company-specific statutory period, pay the applicable fee, and archive the SRN, challan, acknowledgement, filed form, XBRL instance, attachments, Board papers and validation logs.
Frequently Asked Questions on CRA 4 for FY 2025 26
1 Is 27 October 2026 the CRA 4 due date for every 31 March company
No. The company’s statutory filing period is thirty days from its receipt of the cost audit report. A late-September illustration may produce a late-October date, but the actual due date depends on the evidenced receipt date and applicable time-computation rules. The 180-day rule governs when the cost auditor forwards the report to the Board; it is not one common CRA-4 date.
2 Does an emailed draft start the thirty day period
The answer depends on what was delivered and the surrounding record. A discussion draft that is unsigned or lacks required annexures may not be the statutory report, but labels alone are not decisive. The company should document when the complete duly signed report was received and avoid manipulating the receipt record to postpone filing.
3 Can the company file before the Board examines the qualifications
That approach conflicts with the statutory design. Rule 6 requires the Board to consider and examine the report, particularly reservations or qualifications, while section 148(6) requires the company’s information and explanation to accompany the report. The filing package should follow an evidenced Board review and a point-wise response.
4 Which CRA 4 version applies to an October 2026 filing
The form substituted by the Companies (Cost Records and Audit) Amendment Rules, 2025, effective 14 July 2025, applies. The filer should use the live MCA V3 form, current instruction kit and current validation utility at the time of filing rather than a saved legacy form.
5 Does successful MCA validation prove that the report is correct
No. Validation tests format and specified business rules; it does not independently audit the cost records or approve the Board’s explanations. The company and certifying professional remain responsible for the accuracy, completeness and consistency of the submitted information.
6 What should be retained after filing CRA 4
Retain the signed report and annexures, proof of receipt, CRA-2 records, Board agenda and minutes, management responses, source reconciliations, final XBRL instance and rendering, validation logs, signed CRA-4, attachments, professional certification records, SRN, payment challan and acknowledgement. The archive should identify the exact files submitted.
Key Takeaways
- CRA-4 is due within 30 days from the company’s actual receipt of the cost audit report; it has no universal October date.
- The cost auditor’s separate rule 6(5) clock is 180 days from financial-year closure.
- For FY 2025-26, use the CRA-4 form effective from 14 July 2025 and current MCA V3 utilities.
- The Board must examine the report and address every reservation or qualification through a specific, evidenced explanation.
- Reconcile the signed report, XBRL instance, CRA-2 history and CRA-4 before certification and preserve the complete filing audit trail.
Source Links
- Ministry of Corporate Affairs – Companies (Cost Records and Audit) Rules, 2014: https://www.mca.gov.in/Ministry/pdf/rules_2_30062014.pdf
- Ministry of Corporate Affairs – Companies Act, 2013: https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/companies-act-2013.html
- Institute of Cost Accountants of India – Cost Audit Report and Rules resource page: https://icmai.in/ClntMembers/CARR_CAR
- Institute of Cost Accountants of India – MCA notifications on Cost Records and Audit Rules: https://www.icmai.in/ClntMembers/MCA_NotificationsCostRules2014
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Disclaimer: This article is a general educational discussion of Form CRA-4 and the cost audit reporting process for a company with a financial year ending on 31 March 2026, based on the Companies Act, 2013, the Companies (Cost Records and Audit) Rules, 2014 as amended, and publicly available official material checked on 20 October 2026. It does not determine whether any particular company, product, service, plant or activity is subject to maintenance of cost records or cost audit, and it does not fix a filing deadline for an entity whose actual report-receipt facts have not been examined. The 30-day period, the meaning and evidence of receipt, the 180-day auditor obligation, the validity of Board action, the applicable fee and additional fee, the correct MCA V3 form and utility, XBRL taxonomy, professional certification, extensions, portal advisories and consequences of delay must be verified from the law and live official systems at the time of action. Illustrative dates are not legal conclusions. Management, directors, cost auditors, company secretaries and other professionals must independently review the signed report, qualifications, appointment history, Board records, source data, reconciliations, portal version and entity-specific facts. Regulatory law, forms, portal validations and interpretations can change, and a successful upload does not amount to governmental approval of the contents. Readers should obtain advice from a practising cost accountant, company secretary, chartered accountant or legal counsel, as relevant, before filing or responding to a qualification. TaxGuru accepts no responsibility or liability for any error, omission, delay, portal failure, additional fee, penalty, professional consequence, financial loss or other outcome arising from reliance on this article or from action taken without an entity-specific verification of the current law and official records.
