Summary: The Institute of Company Secretaries of India (ICSI), through its President CS Pawan G. Chandak, has represented to the Ministry of Corporate Affairs for introduction of a separate e-Form for filing the appointment and resignation of Secretarial Auditors appointed under Section 204 of the Companies Act, 2013. The representation is dated August 28, 2026 and is addressed to Dr. Pallavi Jain Govil, Hon’ble Secretary, Ministry of Corporate Affairs.
ICSI states that Secretarial Audit has been mandated under Section 204 of the Companies Act, 2013 for specified classes of companies and that the Secretarial Auditor plays an important role in strengthening corporate governance, ensuring regulatory compliance and providing an independent assessment of a company’s compliance framework.
The representation highlights that there is presently no dedicated e-Form under the MCA-21 system for reporting the appointment or resignation of a Secretarial Auditor. ICSI contrasts this with the mechanisms applicable to other statutory auditors and professionals, including Form ADT-1 for intimation of appointment of Statutory Auditor, Form ADT-3 for resignation of Statutory Auditor and Form CRA-2 for appointment of Cost Auditor.
ICSI recommends that the Ministry prescribe a separate e-Form on the lines of ADT-1, ADT-3 and CRA-2 for filing the appointment and resignation/cessation of Secretarial Auditor under Section 204. It suggests that the proposed form may capture the name and registration number of the Secretarial Auditor/Secretarial Audit Firm, date and period of appointment, date and reason for resignation/cessation, wherever applicable, and other requisite particulars.
THE INSTITUTE OF
Company Secretaries of India
IN PURSUIT OF PROFESSIONAL EXCELLENCE
Statutory body under an Act of Parliament
(Under the jurisdiction of Ministry of Corporate Affairs)
G&CL: MCA: AUG:06/2026
August 28, 2026
Dr. Pallavi Jain Govil
Hon’ble Secretary
Ministry of Corporate Affairs
Government of India
New Delhi
Respected Madam,
Subject: Representation for Introduction of a separate e-Form for filing appointment and resignation of Secretarial Auditor appointed under Section 204 of the Companies Act, 2013
Greetings from the Institute of Company Secretaries of India!
The Institute of Company Secretaries of India (ICSI) wishes to draw your kind attention towards the need for prescribing a separate e-Form for filing the appointment and resignation of Secretarial Auditor by the companies which are required to appoint the Secretarial Auditors.
Under the Companies Act, 2013, Secretarial Audit has been mandated for specified classes of companies under Section 204. The Secretarial Auditor plays an important role in strengthening corporate governance, ensuring regulatory compliance and providing an independent assessment of the company’s compliance framework.
Issue
At present, there is no dedicated e-Form prescribed under the MCA-21 system for reporting the appointment or resignation of a Secretarial Auditor. This is in contrast with the mechanism prescribed for other statutory auditors and professionals. For instance, Form ADT-1 is prescribed for intimation of appointment of Statutory Auditor and Form ADT-3 for resignation of Statutory Auditor, while Form CRA-2 is prescribed for appointment of Cost Auditor.
The absence of a similar dedicated form for Secretarial Auditors creates a gap in the statutory reporting mechanism and also makes it difficult to maintain a centralised and readily accessible record of Secretarial Auditors appointed by the companies.
ICSI Submission
In view of the above, ICSI recommends that the Ministry may kindly prescribe a separate e-Form, on the lines of ADT-1/ADT-3 and CRA-2, for filing the appointment and resignation/cessation of Secretarial Auditor under Section 204 of the Companies Act, 2013.
The proposed form may capture relevant particulars such as the name and registration number of the Secretarial Auditor/Secretarial Audit Firm, date of appointment, period of appointment, date and reason for resignation/cessation, wherever applicable, along with other requisite particulars.
Justification
The introduction of such a dedicated e-Form would strengthen the regulatory reporting framework, enhance transparency and facilitate effective monitoring of compliance relating to Secretarial Audit.
A dedicated e-Form would also facilitate greater transparency and accountability by enabling the Ministry, regulatory authorities, stakeholders and investors to readily ascertain the details of the Secretarial Auditor appointed by a company, including the period of appointment and changes arising from resignation or cessation. It would further ensure uniformity in the reporting framework applicable to Statutory Auditors, Cost Auditors and Secretarial Auditors.
The necessity of a separate Form for appointment of Secretarial Auditor would increase with the Corporate Amendment Bill becomes an Act in next few days. The provisions of the Bill allow professionals like Chartered Accountants, Cost Accountants, & Company Secretaries to join hand and have Multi-Disciplinary Partnership Firms, however the Secretarial Audit can only be conducted by the firms which have practising Company Secretaries as its majority partners. To have the proper check & balances and to safeguard the interest of the stakeholders, it is required to have a separate Form for appointment of Secretarial Auditor at par with other professionals.
We shall be happy to provide any further information or clarification that may be desired in this regard.
Thanking you
Yours faithfully,
(CS Pawan G. Chandak)
President
The Institute of Company Secretaries of India
