MCA has vide notification dated 31.03.2022 extends Implementation of Audit Trail software to financial year commencing on or after the April 1, 2023 and also extended CSR-2 due date till May 31, 2022.
Extension of due date for filing form CSR-2
The MCA vide its notification dated 11th February, 2022 had introduced form CSR-2 by inserting sub-rule (1B) in rule 12 of the Companies (Accounts) Rules, 2014.
It was provided that for the preceding F.Y. (2020-21), form CSR-2 shall be filed on or before 31st March 2022, after filing form AOC-4.
However, due to technical difficulties being faced by the stakeholders, the MCA has extended the due date by 2 months by notifying Companies (Accounts) Second Amendment Rules, 2022.
The extended due date for filing form CSR-2 for F.Y. 2020-21 is 31st May, 2022.
Applicability of provisions of Audit Trail
The MCA vide its notification dated 24th March, 2021 had introduced the concept of audit trails by inserting proviso to rule 3(1) of the Companies (Accounts) Rules, 2014.
It was provided that “for the F.Y. commencing on or after 1st April, 2021, every company which uses accounting software for maintaining its books of account, shall use only such accounting software which has a feature of recording audit trail of each and every transaction, creating an edit log of each change made in books of account along with the date when such changes were made and ensuring that the audit trail cannot be disabled.”
However, the applicability was deferred by 1 year by amending the same vide Companies (Accounts) Second Amendment Rules, 2021. The new date of applicability was 1st April, 2022.
Yet again, the MCA has amended the proviso vide Companies (Accounts) Second Amendment Rules, 2022 and has deferred the applicability by 1 more year. Hence the provision of audit trail is now applicable w.e.f. 1st April, 2023.
Full text of the Notification is as follows:-
GOVERNMENT OF INDIA
MINISTRY OF CORPORATE AFFAIRS
NOTIFICATION
New Delhi, the 31st March, 2022
G.S.R. 235(E).-In exercise of the powers conferred by sub-sections (1) and (3) of section 128, sub section (3) of section 129, section 133, section 134, sub-section (4) of section 135, sub-section (1) of section 136, section 137 and section 138 read with section 469 of the Companies Act, 2013 (18 of 2013), the Central Government hereby makes the following rules further to amend the Companies (Accounts) Rules, 2014, namely:-
1. Short title and commencement.- (1) These rules may be called the Companies (Accounts) Second Amendment Rules, 2022.
(2) They shall come into force on the date of their publication in the Official Gazette.
2. In the Companies (Accounts) Rules, 2014,‑
(i) in the proviso to sub-rule (1) of rule 3, for the figures, letters and words “1st day of April, 2022″, the figures, letters and words “1st day of April, 2023″ shall be substituted;
(ii) in the proviso to sub-rule (1B) of rule 12, for the figures, letters and word “31st March, 2022″, the figures, letters and word “31st May, 2022″ shall be substituted.
[F. No. 1/19/2013-CL-V-Part III]
K.V. R. MURTY, Joint Secretary
Note : The principal rules were published in the Gazette of India vide number G.S.R. 239(E), dated the 31st March, 2014 and was subsequently amended vide notifications number G.S.R. 723(E), dated the 14th October, 2014, G.S.R. 37(E), dated the 16th January, 2015, G.S.R. 680(E), dated the 4th September, 2015, G.S.R. 742(E), dated the 27th July, 2016, G.S.R. 1371(E), dated the 7th November, 2017, G.S.R. 191(E), dated the 27th February, 2018, G.S.R. 725(E), dated the 31st July, 2018, G.S.R. 803 (E), dated the 22nd October, 2019, G.S.R. 60 (E), dated the 30th January, 2020, G.S.R. 205(E), dated the 24th March, 2021, G.S.R.247(E), dated the 1st April, 2021 and G.S.R. 107(E), dated the 11th February, 2022.
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