CRA-2 — Cost Auditor Appointment Filing (MCA Intimation within 30 Days)

Companies Act, 2013: Section 148(3) — Board of Directors to appoint a cost auditor within 180 days of start of financial year; intimation to Central Government in Form CRA-2 within 30 days of Board resolution. Section 148(8) — penalty for non-compliance: officer in default: fine ₹25,000 to ₹5 lakh + imprisonment up to 1 year. Companies (Cost Records and Audit) Rules, 2014: Rule 6 — appointment of cost auditor; Form CRA-2; filing on MCA21 within 30 days of Board resolution OR by 30 September (whichever earlier). Rule 6(3A) — cost auditor rotation: maximum 5 consecutive years (firm) before mandatory rotation. Cost auditor qualification: registered Cost Accountant (CMA) with valid Certificate of Practice from the Institute of Cost Accountants of India (ICAI-CMA) — Section 148(3) proviso.

Form CRA-2 is the mandatory intimation to the Central Government (Ministry of Corporate Affairs) of the appointment of a Cost Auditor by a company that is required to conduct a cost audit under Section 148 of the Companies Act, 2013. CRA-2 must be filed on the MCA21 portal within the earlier of: (a) 30 days from the date of the Board of Directors' resolution appointing the cost auditor; or (b) 30 September of the financial year for which the cost auditor is being appointed.

The cost auditor must be a registered Cost Accountant (CMA) — a member of the Institute of Cost Accountants of India (ICAI-CMA) who holds a Certificate of Practice. Only CMAs can be appointed as cost auditors — Chartered Accountants (CAs) from the ICAI cannot hold this position. However, a CA firm assists the company with: (i) identifying and empanelling a qualified CMA firm or cost audit firm; (ii) drafting the Board resolution for cost auditor appointment; (iii) obtaining the CMA's written consent and independence confirmation; (iv) preparing and filing Form CRA-2 on MCA21; and (v) maintaining the cost auditor appointment compliance calendar (annual reappointment or rotation).

The Board resolution for cost auditor appointment must: (a) name the cost auditor (firm name and registration number with ICAI-CMA); (b) specify the financial year for which they are appointed; (c) state the remuneration approved. The CMA must provide a written certificate confirming: that they are not disqualified under Section 141 (which applies to statutory auditors, applied by reference to cost auditors), that no order or proceedings against them are pending with the ICAI-CMA, and that they are not related to any director or officer of the company.

A common compliance gap: many companies appoint a cost auditor verbally or via email but fail to file CRA-2. Section 148(3) explicitly requires the intimation, and the 30-day deadline runs from the Board resolution date — not from the FY start. Missing the deadline triggers the Section 148(8) penalty.