ADT-1 Filing in Bangalore

What is Form ADT-1?

ADT-1 is a notice of appointment. It tells the ROC who your statutory auditor is, for which financial years, under which sub-section of Section 139 they were appointed, and on what date. Once filed, the auditor’s name and the term are visible on the public record against your CIN.

The form also captures compliance confirmations that matter: that the appointment is within the ceiling on the number of company audits an individual auditor may hold, that the auditor is not disqualified under Section 141, and — where an audit committee exists — that its recommendation was considered by the board.

Every company registered under the Companies Act needs a statutory audit every financial year regardless of turnover, so ADT-1 is not a filing only large companies deal with. A dormant-looking first year still needs an auditor, an audit, and this filing.

When must the first auditor be appointed?

For a company other than a government company, the board of directors appoints the first statutory auditor within 30 days of the date of registration. This is fixed in Section 139(6) and it is the earliest hard deadline a new company faces — earlier than the 180-day commencement of business declaration.

If the board fails to appoint within those 30 days, the power shifts to the members, who must appoint within 90 days at an extraordinary general meeting. Either way the first auditor holds office only until the conclusion of the first annual general meeting, at which the members make a fresh appointment.

Before the resolution is passed you need the auditor’s written consent and a certificate that they are eligible and not disqualified. The board resolution should record the auditor’s name, firm registration number, and the financial year the appointment covers.

Is ADT-1 mandatory for the first auditor?

This is a genuinely unsettled point and worth stating precisely. The obligation to notify the Registrar comes from the fourth proviso to Section 139(1), and Rule 4(2) says that notice shall be in Form ADT-1. Section 139(1) deals with appointment by the members; the first auditor is appointed under Section 139(6), which carries no corresponding notice requirement.

The revised ADT-1 deployed in July 2025 nonetheless includes "First auditor by Board of directors / members / C&AG" as a nature-of-appointment option, which created uncertainty about whether the filing had become compulsory. ICSI made a representation seeking clarification, and MCA’s own FAQ acknowledges that Rule 4(2) refers to Section 139(1) and not Section 139(6) while recommending that companies file ADT-1 even for a first auditor.

Our position is to file it. It is inexpensive, it puts the appointment on record, and it removes a downstream problem: several later forms ask for the SRN of the earlier ADT-1. Where no ADT-1 was filed for a first auditor, MCA’s FAQ permits Z99999999 to be entered in place of the missing SRN — a workaround that exists precisely because so many first appointments were never filed. Past non-filing should not automatically be treated as a statutory default, but there is no advantage in leaving the gap open.

When is ADT-1 due for an auditor appointed at the AGM?

Where the members appoint an auditor at an annual general meeting, the company must inform the auditor of the appointment and file the notice with the Registrar within 15 days of the meeting at which the appointment was made. The 15 days run from the AGM date, not from the financial year end.

An auditor appointed at an AGM under Section 139(1) holds office from that AGM until the conclusion of the sixth AGM — a five-year term. Because the appointment is for a block of years, you do not file a fresh ADT-1 each year of the term; the next filing comes at the end of the block, on a casual vacancy, or on any other change in the appointment.

ADT-1 is therefore the third of the three AGM-triggered filings, alongside AOC-4 and MGT-7 at 30 and 60 days. It has the shortest window of the three and is the one most often missed.

What are the ADT-1 due dates by appointment type?

The table shows the common cases for a private or unlisted public company. Government companies follow a different appointment route through the Comptroller and Auditor General and are outside this pattern.

What documents are required for ADT-1 filing?

• Written consent of the auditor to the appointment
• Certificate from the auditor under Section 141 confirming eligibility and no disqualification
• Certified copy of the board resolution or the shareholder resolution making the appointment
• Intimation letter sent by the company to the auditor recording the appointment
• Auditor’s membership number and firm registration number
• The financial year or years for which the appointment runs
• SRN of the previous ADT-1 where the form asks for it, or Z99999999 where no earlier filing exists
• SRN of any INC-28 where the appointment follows a Tribunal order
• DSC of the authorised director or company secretary

One field that causes avoidable errors: the form asks for the financial year start and end dates of the appointment, not the date of the AGM. Entering the AGM date there is one of the more common corrections we see.

How to file ADT-1 step by step?

1. 1.Identify the sub-section under which the appointment is being made — first auditor, AGM appointment, or casual vacancy
2. 2.Obtain the auditor’s written consent and eligibility certificate under Section 141
3. 3.Where an audit committee exists, place its recommendation before the board
4. 4.Pass the board resolution, and where the appointment is by the members, put the item in the AGM or EGM notice with the explanatory statement
5. 5.Hold the meeting and pass the resolution
6. 6.Send the intimation letter to the auditor
7. 7.Open Form ADT-1 on MCA V3 and select the correct nature of appointment
8. 8.Enter the auditor details, membership and firm registration numbers, and the financial years covered
9. 9.Attach the consent, eligibility certificate and resolution
10. 10.Sign with DSC and submit within 15 days of the appointing meeting
11. 11.Save the SRN — later ADT filings and change-of-auditor forms will ask for it

What is auditor rotation and does it apply to us?

Section 139(2) requires mandatory rotation of auditors for listed companies and for other prescribed classes of company measured by paid-up capital, turnover or borrowings. An individual auditor may hold office for one term of five consecutive years, and an audit firm for two consecutive terms of five years, after which a cooling-off period applies before reappointment.

Most small private companies sit outside rotation and can reappoint the same auditor block after block. The thresholds that pull a company into rotation are prescribed in the rules and have been revised, so if your company is growing, test the position each year rather than assuming you remain exempt. ADT-1 asks whether the company falls within any class covered by Section 139(2), and answering it wrongly is a misstatement on the form.

What is the difference between ADT-1, ADT-2 and ADT-3?

Removing an auditor mid-term is deliberately difficult. It needs a board resolution, an application for Central Government approval routed through the Regional Director, and then a special resolution of the members — in that order. A resignation, by contrast, is the auditor’s own act and their own filing, but it leaves the company with a casual vacancy it must fill within 30 days and get approved by members within three months.

If your auditor has resigned mid-year, the sequence is ADT-3 from them, a board appointment, ADT-1 from you, then a members’ resolution. Missing the member approval leg is a frequent gap.

What are the consequences of not filing ADT-1?

The immediate consequence is the additional fee. ADT-1 carries the ordinary MCA fee slabbed by share capital, and a delayed filing attracts an additional fee that rises as a multiple of the normal fee with the length of the delay — up to the highest slab for delays beyond the prescribed period.

• An escalating additional fee on the form, rising with the delay
• Penalty exposure under Section 147 for contravention of the audit provisions, on the company and on officers in default
• A missing SRN that blocks or complicates later ADT filings and change-of-auditor forms
• Questions in diligence about whether the auditor was validly appointed for the years audited
• Difficulty demonstrating a valid appointment if the audit report is later challenged

Note the distinction from the annual filing forms: ADT-1 delay is charged as a multiple of the normal fee rather than a flat uncapped daily amount. That makes it cheaper to correct late than AOC-4 or MGT-7 — but it does not make the underlying default harmless.

How much does ADT-1 filing cost?

The fee slabs and multiples in the Companies (Registration Offices and Fees) Rules are amended from time to time, so the figures above are indicative and confirmed on the portal before filing. Statutory audit fees paid to the auditor are separate and are negotiated directly with them.

What should be checked before appointing an auditor?

1. 1.Confirm the auditor is a chartered accountant in practice or a firm whose partners practising in India are chartered accountants
2. 2.Check they are not disqualified under Section 141 — no business relationship, indebtedness beyond the prescribed limit, or conflicting interest
3. 3.Confirm the appointment is within the ceiling on the number of company audits the individual may hold
4. 4.Obtain the written consent and the eligibility certificate before the resolution, not after
5. 5.Establish whether your company falls within any class covered by mandatory rotation
6. 6.Agree the scope — statutory audit only, or also tax audit and other certification
7. 7.Record the financial years the appointment covers in the resolution itself
8. 8.Diarise the ADT-1 date for 15 days from the meeting

Where the incoming auditor is replacing an outgoing one, also confirm that the outgoing auditor has filed ADT-3 or that the non-reappointment is properly recorded, so the MCA record does not show two auditors for the same period.

What is changing in auditor appointment filings?

ADT-1 was substituted with a revised form effective from 14 July 2025 as part of the migration of the audit forms to MCA V3. The revision added the first-auditor option in the nature-of-appointment field and reorganised the compliance confirmations. The underlying Rule 4(2) was not amended, which is the source of the mandatory-or-not question discussed above, and ICSI’s representation seeking clarification remains the most useful summary of the open point.

Separately, MCA has been consulting on a broader rationalisation of the filing framework under the Companies Act. The draft Companies (Incorporation) Amendment Rules, 2026 currently in consultation deal with incorporation, change and conversion forms rather than the audit forms, so they do not touch ADT-1. Nothing here is notified law yet — file on the current form and current rules.

Why choose Arjun Filings for ADT-1 filing?

Arjun Filings runs ADT-1 filing as a checklist-first engagement: a qualified CA or CS scopes the work, tells you exactly which documents are needed, and reviews every form before it is signed and submitted. You get a named specialist, a status update at each stage, and a compliance calendar for whatever comes next.

• Specialist support for ADT-1 filing
• Due-date calendar and penalty awareness
• Form review before DSC signing
• Status updates until acknowledgement