Secretarial Audit Services

Independent compliance assurance under Section 204 of the Companies Act, 2013

What is Secretarial Audit?

Secretarial Audit is an independent and objective assurance mechanism mandated under Section 204 of the Companies Act, 2013 read with Rule 9 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014. It is a process of verifying whether a company has complied with the provisions of various corporate laws, rules, regulations, and guidelines.

The Secretarial Audit Report is issued in Form MR-3 by a Practicing Company Secretary (PCS) and is attached to the Board's Report of the company. It provides stakeholders with an independent opinion on the company's compliance status.

At Deepa Sharma & Associates, our qualified PCS conducts thorough secretarial audits, identifying compliance gaps and providing actionable recommendations to strengthen your governance framework.

Who Needs a Secretarial Audit?

Listed Companies

Every company whose securities are listed on a recognized stock exchange in India is required to obtain a Secretarial Audit Report.

Public Companies

Every public company having a paid-up share capital of ₹50 crore or more, OR a turnover of ₹250 crore or more.

Private Companies

Every private company having a paid-up share capital of ₹50 crore or more, OR a turnover of ₹250 crore or more (as per Companies Amendment Rules, 2020).

Subsidiary Companies

Every subsidiary of a listed company that falls under the prescribed threshold of paid-up capital or turnover criteria.

Objectives of Secretarial Audit

  • To verify compliance with the Companies Act, 2013 and rules made thereunder
  • To examine compliance with SEBI regulations and listing requirements (for listed companies)
  • To check adherence to FEMA provisions and RBI guidelines
  • To ensure proper maintenance of statutory records and registers
  • To verify that board processes and governance structures are adequate
  • To provide independent assurance to stakeholders on the company's compliance health

Advantages of Secretarial Audit

Early Risk Detection

Identifies non-compliances and potential risks before they escalate into penalties or regulatory actions.

Governance Strengthening

Helps improve corporate governance practices and internal processes through expert recommendations.

Stakeholder Confidence

Provides assurance to shareholders, investors, and regulators about the company's compliance status.

Penalty Avoidance

Timely identification and rectification of lapses helps avoid hefty penalties and prosecution under the Act.

Due Diligence Support

A clean secretarial audit report facilitates smoother due diligence during fundraising, M&A, or IPO processes.

Board Accountability

Ensures the Board is aware of its obligations and promotes a culture of compliance within the organization.

Auditor Qualification

The Secretarial Audit can only be conducted by a Practicing Company Secretary (PCS) — a member of the Institute of Company Secretaries of India (ICSI) holding a Certificate of Practice.

The PCS must be independent and should not have any pecuniary relationship with the company other than the audit fee. The appointment is made by the Board of Directors through a Board Resolution.

Report Format: Form MR-3

The Secretarial Audit Report is issued in Form MR-3 as prescribed under the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014. The report must be annexed to the Board's Report filed with the Registrar of Companies.

Penalties for Non-Compliance

If a company fails to get a Secretarial Audit conducted:

  • Company: Fine of ₹1 lakh to ₹5 lakh
  • Officers in Default: Fine of ₹1 lakh to ₹5 lakh, or imprisonment up to 1 year, or both
  • PCS (if provides false report): Liable for disciplinary action and penalties under Section 448

Frequently Asked Questions

Is Secretarial Audit mandatory for all companies?

No, Secretarial Audit is mandatory only for listed companies, public companies with paid-up capital ≥ ₹50 crore or turnover ≥ ₹250 crore, and private companies meeting the same thresholds. However, any company can voluntarily get a Secretarial Audit conducted for better governance.

What is the difference between Secretarial Audit and Statutory Audit?

Statutory Audit (conducted by a Chartered Accountant) focuses on financial statements and accounting records. Secretarial Audit (conducted by a PCS) focuses on compliance with corporate laws, board processes, statutory filings, and governance practices. Both serve different but complementary purposes.

When should the Secretarial Audit Report be filed?

The Secretarial Audit Report (Form MR-3) must be annexed to the Board's Report, which is filed as part of the Annual Return with the ROC. It should be completed before the Board meeting that approves the annual financial statements.

Can the same PCS conduct Secretarial Audit every year?

Yes, there is no mandatory rotation requirement for the Secretarial Auditor under the Companies Act. However, for listed companies, SEBI guidelines may recommend periodic rotation. The Board re-appoints the auditor each year through a resolution.

What documents are reviewed during a Secretarial Audit?

The PCS reviews MOA/AOA, Board and General Meeting minutes, statutory registers, ROC filings, contracts, related party transactions, regulatory correspondence, share transfer records, annual returns, and compliance with specific industry regulations applicable to the company.

Need a Secretarial Audit?

Our qualified PCS provides thorough, timely secretarial audit services with actionable compliance insights.