CRA-2 and CRA-4 Deadlines for FY 2025-26: September 27 & October 27, 2026
Companies covered under the Companies (Cost Records and Audit) Rules, 2014 must file Form CRA-2 by September 27, 2026 and Form CRA-4 by approximately October 27, 2026 for FY 2025-26. Here is who is covered, the turnover thresholds under Table A and Table B, and the penalties for missing either deadline.
CA Harun Raaj
Chartered Accountant · Harun Raaj & Associates
Legal basis: Companies Act, 2013 — Section 148, read with the Companies (Cost Records and Audit) Rules, 2014 (Rules 3, 4 and 6), as amended by the Companies (Cost Records and Audit) Amendment Rules, 2025 — Effective: July 14, 2025 (amendment); ongoing (principal rules). Source: MCA.gov.in. Last reviewed by CA Harun Raaj: September 2026.
Companies covered under the Companies (Cost Records and Audit) Rules, 2014 face two connected deadlines for the financial year ending March 31, 2026: Form CRA-2 by September 27, 2026 and Form CRA-4 by approximately October 27, 2026. Missing either attracts escalating penalties under the Companies Act, 2013. Whether your company is even covered depends on turnover thresholds that change by sector — and on last year's numbers, not this year's.
What Are CRA-2 and CRA-4?
Form CRA-2 is the intimation of cost auditor appointment, filed with the Ministry of Corporate Affairs (MCA). Under Rule 6(2) of the Companies (Cost Records and Audit) Rules, 2014, read with Section 148(3) of the Companies Act, 2013, a company must file CRA-2 within 180 days of the commencement of the financial year to intimate the appointment or re-appointment of its cost auditor. For FY 2025-26, commencing April 1, 2025, 180 days works out to September 27, 2026.
Form CRA-4 is the filing of the cost audit report with the MCA. Under Rule 6(6), the cost auditor submits the cost audit report to the company's Board in Form CRA-3 within 180 days of the financial year end — also September 27, 2026 for a March-ending FY. The company must then file CRA-4 within 30 days of the Board receiving CRA-3, which works out to approximately October 27, 2026.
The MCA revised both forms through the Companies (Cost Records and Audit) Amendment Rules, 2025, effective July 14, 2025. The revised CRA-2 requires additional disclosures, including the category of appointment (fresh or re-appointment) and a consent declaration from the cost auditor. Companies must use the updated forms for FY 2025-26 filings.
Who Must Comply?
The Rules split companies into two categories, each with a separate threshold for maintaining cost records (CRA-1) and for the cost audit itself.
Key point: Both the CRA-1 maintenance obligation and the CRA-2 onwards cost audit obligation are triggered by the immediately preceding financial year's turnover, not the current year's.
What You Need to Do Right Now
If your company falls within Table A or Table B thresholds above, the sequence for FY 2025-26 is straightforward but time-bound:
- Confirm the cost auditor's appointment (if not already done). The cost auditor must hold a valid Certificate of Practice from the Institute of Cost Accountants of India (ICMAI), and cannot be the company's statutory auditor or a partner or employee of the statutory auditor's firm, per Rule 6(1).
- File CRA-2 by September 27, 2026 through the MCA21 portal (V3), using the revised form effective July 14, 2025, with the Board Resolution authorising the appointment and the cost auditor's written consent attached.
- Ensure CRA-3 is ready by September 27, 2026. Share Q4 trial balances, production records, and product costing data with the cost auditor well ahead of this date so the Board receives the report on time.
- File CRA-4 within 30 days of the Board receiving CRA-3 — targeting approximately October 27, 2026 if CRA-3 arrives on schedule.
Penalties for Non-Compliance
Under Section 148(8) read with Section 137/92 of the Companies Act, 2013, as amended by the Companies (Amendment) Act, 2020:
- Default in filing CRA-4 attracts a fine of ₹10,000 on the company, plus a further ₹100 per day up to a maximum of ₹2 lakh on the company; officers in default face a fine of up to ₹50,000.
- Small companies (paid-up capital up to ₹4 crore and turnover up to ₹40 crore) get the penalty reduced to half under Section 446B.
- The MCA has been issuing suo-motu inspection notices to companies with a pattern of CRA-4 non-compliance.
A Practical Illustration
Ratan Pharma Ltd, a Mumbai-based pharmaceutical manufacturer with FY 2024-25 turnover of ₹85 crore, sits in Table A. It must maintain cost records under CRA-1 and undergo a cost audit. It appointed its cost auditor on April 15, 2026 but has not yet filed CRA-2, and has until September 27, 2026 to do so. If it also missed CRA-4 for FY 2024-25 — due around October 27, 2025 — an MCA notice is a live risk. (Illustrative example only.)
The deadlines themselves are procedural, but they sit on top of substantive work — costing systems, product-level records, and a cost audit that a qualified Cost Accountant must independently form a view on. Getting the Board to receive CRA-3 by September 27 depends on the company supplying accurate, timely data well before that date, not on the filing step alone.
I'm CA Harun Raaj, Visakhapatnam. If your company is tracking towards these CRA-2 or CRA-4 deadlines, reach out and we'll help you map the timeline against your specific turnover history.
---
See Also
- Cost Audit Compliance 2026: CFOs and Directors Now Face Personal Penalties Under the Corporate Laws Amendment Bill
- Standard Costing for Manufacturers: Bridging Product Costs and Transfer Pricing Under Section 92C
- DPCO Compliance for Pharma: Cost Statement Format, Ceiling Price Reporting & NPPA Rules
Frequently Asked Questions
When is Form CRA-2 due for FY 2025-26?
Form CRA-2 is due within 180 days of the start of the financial year under Rule 6(2) of the Companies (Cost Records and Audit) Rules, 2014, read with Section 148(3) of the Companies Act, 2013. For FY 2025-26, commencing April 1, 2025, this works out to September 27, 2026.
When must Form CRA-4 be filed for FY 2025-26?
Form CRA-4 must be filed within 30 days of the Board receiving the cost auditor's report in Form CRA-3, per Rule 6(6). Since CRA-3 is due by September 27, 2026, CRA-4 works out to approximately October 27, 2026, assuming the Board receives CRA-3 on schedule.
My company's turnover just crossed ₹100 crore this year (FY 2025-26). Do I need to file CRA-2 now?
Applicability is based on the turnover of the immediately preceding financial year, i.e. FY 2024-25. If FY 2024-25 turnover was below the applicable threshold, there is no cost audit obligation for FY 2025-26, but the FY 2025-26 turnover should be monitored for next year's applicability.
Our company is in the construction sector (Table B). Are we exempt from cost audit?
Construction companies fall under Table B of the Companies (Cost Records and Audit) Rules, 2014. If FY 2024-25 turnover was below the Table B cost audit threshold of ₹100 crore, there is no cost audit obligation for FY 2025-26, though the cost records maintenance threshold of ₹35 crore under Rule 3 may still apply.
Can the statutory auditor also act as cost auditor?
No. Rule 6(1) of the Companies (Cost Records and Audit) Rules, 2014 bars the cost auditor from being the company's statutory auditor or a partner or employee of the statutory auditor's firm.
What happens if the cost auditor submits CRA-3 after September 27, 2026?
A late CRA-3 pushes the CRA-4 filing timeline back, since CRA-4 is due 30 days from the Board's actual receipt of CRA-3. Companies should follow up with the cost auditor well before September 27, 2026 and keep correspondence on record in case of delay.
Is the penalty for missing CRA-4 reduced for small companies?
Yes. Under Section 446B of the Companies Act, 2013, small companies — defined as those with paid-up capital up to ₹4 crore and turnover up to ₹40 crore — get the CRA-4 default penalty reduced to half of the amounts specified under Section 148(8).
Need help with this?
Our team handles the paperwork. You focus on your business.