Last reviewed: 14 November 2026. On 27 October 2026 the Ministry of Corporate Affairs issued General Circular No. 06/2026 (File No. Policy-17/52/2020-CL-V), titled "Relaxation of additional fees and extension of time for filing CRA-4 (Cost Audit Report in XBRL format)". For the financial year 2025-26, CRA-4 filed up to 31 December 2026 will not attract any additional fees. This note explains what the circular covers, which companies are actually within cost audit, how the fee clock works if the window is missed, and a working plan for the next six weeks.
What the circular says
The circular is short and has two operative paragraphs. Keeping in view requests from stakeholders for more time to file the cost audit report for FY 2025-26, the Ministry has decided that any filing of CRA-4 for that year made up to 31 December 2026 would not attract payment of any additional fees. Paragraph 2 then states the consequence of missing the date: filings made after the circular ceases to apply attract all fees, including additional fees, as provided in the Companies (Registration Offices and Fees) Rules, 2014, from the date when such filings were actually due under Rule 6(6) of the Companies (Cost Records and Audit) Rules, 2014.
Two practical points follow. First, this is a waiver of additional fees, not a change in the statutory due date. Second, the waiver is conditional on filing inside the window. A company that files on 5 January 2027 does not pay from 1 January; it pays from the original Rule 6(6) due date.
The cost audit timeline in one table
| Step | Form | Who | Time limit |
|---|---|---|---|
| Appointment of cost auditor and intimation to the Central Government | CRA-2 | Board / company | 30 days of the Board meeting, or 180 days from the start of the financial year, whichever is earlier |
| Cost audit report to the Board | CRA-3 | Cost auditor | Within 180 days from the close of the financial year (Rule 6(4)) |
| Cost audit report furnished to the Central Government with explanations on reservations | CRA-4 (XBRL) | Company | Within 30 days from the date of receipt of the report (section 148(6), Rule 6(6)) |
Because the CRA-4 clock runs from the date the Board actually receives the report, there is no single calendar date for every company. A company whose report was received on 20 September 2026 had a due date of 20 October 2026. A company that received it on 15 November 2026 has a due date of 15 December 2026. The circular's 31 December 2026 date is the outer limit for the fee relief in either case.
Who is within cost audit at all
The circular helps only companies that are already required to get a cost audit done. The applicability tests sit in Rules 3 and 4 of the Companies (Cost Records and Audit) Rules, 2014. They are separate tests, and many companies keep cost records without needing a cost audit.
| Test | Regulated sectors (Table A) | Non-regulated sectors (Table B) |
|---|---|---|
| Cost records (Rule 3) | Overall turnover of Rs 35 crore or more in the immediately preceding financial year, for specified products or services | |
| Cost audit: overall turnover (Rule 4) | Rs 50 crore or more | Rs 100 crore or more |
| Cost audit: turnover of the covered product or service | Rs 25 crore or more | Rs 35 crore or more |
Cost audit does not apply to a company covered by the Rules if its revenue from exports in foreign exchange exceeds 75% of its total revenue, or if it operates from a special economic zone. Note that these exemptions apply to the audit under Rule 4; cost records may still be required. The applicable sector entries, the micro and small enterprise position and any later amendments should be checked against the current text of the Rules for the company concerned.
Take a manufacturer in a non-regulated sector with overall turnover of Rs 140 crore in FY 2024-25, of which the covered product contributes Rs 48 crore. Both limits are crossed, exports are 10% of revenue and it is not in an SEZ, so a cost audit for FY 2025-26 is required and CRA-4 is in play. A similar manufacturer with overall turnover of Rs 90 crore needs cost records but no cost audit, and has nothing to file in CRA-4.
What the circular does not change
- The cost auditor's timeline. The report to the Board is still due within 180 days of year end. For FY 2025-26 that period ended on 27 September 2026. A report not yet delivered is a compliance gap that the circular does not address.
- The statutory CRA-4 due date. It stays at 30 days from receipt. The relief is on fees only.
- CRA-2 and CRA-3. Not covered. Appointment intimation and the cost auditor's report keep their own timelines.
- Normal filing fee. Still payable. Only the additional fee is waived.
- Other years. The relief is limited to FY 2025-26.
- Accuracy. The XBRL instance document, the cost statements and the management's explanations on every reservation or qualification must still be complete and consistent with the cost auditor's signed report.
How the additional fee works if the window is missed
For delay in filing, the fees rules prescribe an additional fee that is a stepped multiple of the normal fee, rising with the length of the delay. The circular does not reduce those multiples; it simply waives them for filings made by 31 December 2026. If the date is missed, the delay is measured from the original Rule 6(6) due date.
| Illustration | Report received by Board | Original CRA-4 due | Filed on | Position |
|---|---|---|---|---|
| A | 27 Sep 2026 | 27 Oct 2026 | 10 Dec 2026 | Inside window. No additional fee |
| B | 27 Sep 2026 | 27 Oct 2026 | 12 Jan 2027 | Outside window. Delay runs from 27 Oct 2026, about 77 days, and the additional fee is computed on that |
| C | 15 Nov 2026 | 15 Dec 2026 | 28 Dec 2026 | Inside window. No additional fee |
The exact additional fee for a late filing is calculated by the MCA21 payment screen at the time of filing, and that figure should be treated as final.
Working plan for the next six weeks
| Step | What to do | Target |
|---|---|---|
| 1 | Confirm whether the company is within cost audit for FY 2025-26 using the Rule 3 and Rule 4 tests above, and record the conclusion with the turnover workings. | This week |
| 2 | Check that the cost auditor's signed report has been placed before the Board, and note the date of receipt. That date fixes the Rule 6(6) due date. | This week |
| 3 | Prepare management's explanation for every reservation, qualification or observation, and get Board approval of the cost statements. | By 25 November |
| 4 | Complete the XBRL instance document and validate it. Keep the digital signature of the authorised signatory ready. | By 5 December |
| 5 | File CRA-4, pay the normal fee, and confirm the SRN is approved and not merely generated. | By 15 December |
| 6 | Keep a buffer of two weeks for rejection or resubmission before 31 December. | Reserve |
The same 31 December 2026 date applies to the AOC-4 family under a separate circular. Companies with both filings pending should expect portal load in the last week of the year. Our note on General Circular 05/2026 for AOC-4 and MGT-7 sets out that relief, and the annual ROC compliance guide for private companies gives the full year-end checklist. Companies that also need to test the separate Section 138 requirement can read our internal audit guide for private companies.
Common mistakes to avoid
- Treating 31 December 2026 as a new statutory due date, rather than the last day of a fee waiver.
- Assuming the additional fee starts from 1 January 2027 if the window is missed.
- Counting the 30 days from the financial year end instead of from the date the Board received the report.
- Filing the XBRL with figures that do not tally with the cost statements approved by the Board.
- Leaving management's response to the cost auditor's reservations blank or generic.
- Concluding that cost audit applies on turnover alone, without checking the sector entries and the export and SEZ exemptions.
Frequently asked questions
What has MCA announced for CRA-4 for FY 2025-26?
General Circular No. 06/2026 dated 27 October 2026 (File No. Policy-17/52/2020-CL-V) provides that any filing of CRA-4, the Cost Audit Report in XBRL format, for FY 2025-26 made up to 31 December 2026 will not attract payment of any additional fees.
Is the normal CRA-4 filing fee also waived?
No. The circular relaxes additional fees only. The normal fee prescribed under the Companies (Registration Offices and Fees) Rules, 2014 continues to apply. Check the amount on the MCA21 payment screen before submitting.
What happens if CRA-4 is filed after 31 December 2026?
The circular says that filings made after its currency attract all fees, including additional fees, from the date the filing was actually due under Rule 6(6) of the Companies (Cost Records and Audit) Rules, 2014. The additional fee is therefore counted from the original due date, not from 1 January 2027.
Does the circular extend the 180-day period for the cost auditor's report?
No. The circular deals only with the fee for filing CRA-4. The cost auditor must still submit the report to the Board within 180 days of the close of the financial year under Rule 6(4), and the Board's duty to furnish it to the Central Government under section 148(6) is unchanged.
Which companies need a cost audit?
Companies in the sectors listed in the Cost Records and Audit Rules, 2014 that cross the turnover limits: for regulated sectors, overall turnover of Rs 50 crore or more and Rs 25 crore or more from the covered product or service; for non-regulated sectors, Rs 100 crore and Rs 35 crore. Cost audit does not apply if exports in foreign exchange exceed 75% of total revenue or the company operates from a special economic zone.
Does this circular apply to CRA-2 or CRA-3?
No. It covers CRA-4 only, for FY 2025-26. Intimation of the cost auditor's appointment and the cost auditor's own report keep their existing timelines.
Is the circular also a relief for AOC-4 and MGT-7?
Not by itself. AOC-4 and MGT-7 were dealt with separately by General Circular No. 05/2026 dated 24 October 2026, which allows AOC-4 till 31 December 2026 and MGT-7 or MGT-7A till 31 January 2027 without additional fees.
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ROC Filing ServicesBookkeeping and AccountingTalk to usThis article summarises MCA General Circular No. 06/2026 dated 27 October 2026 for general information and is not professional advice. The cost audit itself must be carried out by a Cost Accountant in practice appointed under section 148. Check the circular text on the MCA website and your company's own facts before filing. Filing is prepared on the basis of information and documents supplied by the company. Consult a professional for your specific situation.