Every company incorporated in India must have a statutory auditor. And every time an auditor is appointed or reappointed, the company is required to inform the Registrar of Companies. That information is submitted through Form ADT-1.
It is one of the shorter compliance obligations in the annual ROC calendar, but the window to file it is tight, the penalties for missing it accumulate daily, and a rejected filing because of a missing document or a wrong detail can push a company past the deadline without them realising it.
This guide covers everything you need to know about Form ADT-1, including who files it, when, what documents are required, what it costs, and what happens if it is filed late.
What is Form ADT-1?
Form ADT-1 is the statutory notice that a company files with the Ministry of Corporate Affairs (MCA) to inform the Registrar of Companies about the appointment of its auditor. It is governed by Section 139(1) of the Companies Act, 2013, and must be filed within 15 days of the auditor’s appointment.
The form captures basic but important information:
- Category of auditor (whether an individual CA or a CA firm)
- PAN of the auditor or Firm Registration Number (FRN) of the firm
- Membership number of the auditor
- Name and address of the auditor
- Period of appointment and date of appointment
- Date of the AGM at which the appointment was made
- Details of any casual vacancy, including the date and reason, and membership number of the outgoing auditor
The responsibility to file Form ADT-1 lies entirely with the company, not the auditor.
Who Needs to File
All companies registered in India are required to file Form ADT-1 when appointing an auditor. This includes:
- Private limited companies
- Public limited companies
- One Person Companies (OPCs)
- Listed companies
There is a commonly held view that Form ADT-1 is not required for the appointment of the first auditor, because Rule 4(2) of the Companies (Audit and Auditors) Rules, 2014 specifically references Section 139(1) which covers subsequent appointments, not Section 139(6) which covers the first auditor. In practice, however, filing ADT-1 for the first auditor appointment is considered good compliance practice and most professionals recommend doing so.
When to File Form ADT-1
The 15-day clock starts from the date of auditor appointment. The specific trigger depends on the type of appointment:
- AGM appointment or reappointment: File within 15 days of the AGM date. If the AGM was held on 29 September, the deadline is 14 October.
- First auditor (appointed by the Board): File within 15 days of the board meeting at which the first auditor was appointed, which must happen within 30 days of incorporation.
- Casual vacancy (resignation or removal of previous auditor): File within 15 days of the board meeting that appointed the replacement auditor.
There is no grace period. Penalties begin accruing from day 16.
Documents Required for Filing
Before filing Form ADT-1, the following documents must be ready and attached in PDF format:
- Board resolution or AGM resolution: The resolution approving the auditor’s appointment, specifying the name, audit fee, and tenure.
- Auditor’s written consent: A letter from the auditor or audit firm accepting the appointment, on their letterhead.
- Section 141 certificate: A declaration by the auditor confirming they are not disqualified from appointment under Section 141 of the Companies Act, 2013. This covers eligibility criteria such as independence, not holding interests in the company, and not being in default of any regulatory requirements.
- Appointment letter: The formal letter issued by the company to the auditor confirming the terms of appointment.
For casual vacancy situations, the resignation letter or removal resolution of the outgoing auditor is also required.
Digital signatures needed:
- Digital Signature Certificate (DSC) of the director authorised to file
- DSC of the auditor or the signing partner of the audit firm
All documents must be digitally signed. Unsigned attachments are one of the most common reasons for rejection.
Filing Fees
The MCA filing fee for Form ADT-1 is based on the company’s authorised share capital:
| Authorised Share Capital | Filing Fee |
| Less than ₹1,00,000 | ₹200 |
| ₹1,00,000 to ₹4,99,999 | ₹300 |
| ₹5,00,000 to ₹24,99,999 | ₹400 |
| ₹25,00,000 to ₹99,99,999 | ₹500 |
| ₹1,00,00,000 or more | ₹600 |
| Companies with no share capital | ₹200 |
These are the base fees for timely filing. Late filing attracts a multiplier on top of this base fee.
Penalties for Late Filing
Form ADT-1 attracts two types of penalty when filed late: an escalating additional fee on the MCA portal, and a daily penalty under the Companies Act.
Additional MCA fee (multiplier on base fee):
| Delay Period | Additional Fee |
| Up to 30 days late | 2x the normal fee |
| 31 to 60 days late | 4x the normal fee |
| 61 to 90 days late | 6x the normal fee |
| 91 to 180 days late | 10x the normal fee |
| Beyond 180 days | 12x the normal fee |
Daily penalty under the Companies Act:
In addition to the portal fees, late filing of Form ADT-1 attracts a penalty of ₹100 per day on the company and ₹100 per day per director in default. There is no ceiling on this daily penalty, meaning it continues to accumulate for as long as the form remains unfiled.
Example: If a company with three directors misses the deadline by 45 days:
- Additional MCA fee (4x on ₹400 base): ₹1,600
- Daily penalty on company (45 days x ₹100): ₹4,500
- Daily penalty on each director (45 days x ₹100 x 3 directors): ₹13,500
- Total: ₹19,600
That compares to a timely filing cost of ₹400. The math for filing on time is not complicated.
Beyond the financial cost, non-filing of Form ADT-1 can also result in director disqualification under Section 164(2) for persistent default, DIN deactivation, and a compliance flag on MCA records that surfaces in investor due diligence.
How to File Form ADT-1 on MCA V3
As of March 2026, all MCA filings including Form ADT-1 are processed on the MCA V3 portal. The legacy V2 platform has been decommissioned. Here is the filing process:
Step 1: Log in to the MCA V3 portal at mca.gov.in using Business User credentials.
Step 2: Navigate to the e-Forms section and select Form ADT-1. The V3 portal pre-fills company details such as CIN, registered office, and director information. Verify all pre-filled data before proceeding.
Step 3: Fill in the auditor details including category (individual or firm), PAN or FRN, membership number, address, and the tenure and date of appointment.
Step 4: Attach all required documents in PDF format. Each attachment must be digitally signed. Check file sizes, as the portal enforces upload limits.
Step 5: Attach the DSC of the authorised director and, where required, the DSC of the auditor.
Step 6: Use the form validation tool to run a pre-submission check. Address any errors flagged before submitting.
Step 7: Submit the form. A Service Request Number (SRN) is generated, which can be used to track the processing status.
Step 8: Pay the filing fee through the payment gateway. Payment can be made by net banking, debit/credit card, or NEFT/RTGS. The form is auto-approved on the MCA portal once fees are paid and no discrepancies are detected.
An acknowledgement with the transaction number is sent to the company’s registered email ID. Keep this acknowledgement, as it serves as proof of filing.
Common Reasons for Rejection
Form ADT-1 has a relatively high rejection rate when filed without professional assistance. The most frequent reasons include:
- Incorrect CIN: A typographical error in the Corporate Identity Number.
- Director DSC mismatch: The director signing the form is not the same as the one authorised in the board resolution.
- Invalid FRN: The audit firm’s registration number is expired, inactive, or entered incorrectly.
- Missing or unsigned attachments: The Section 141 certificate, consent letter, or appointment letter is absent or lacks a valid digital signature.
- AGM date mismatch: The date entered in the form does not match the AGM minutes.
- Incorrect tenure: The audit tenure period is stated incorrectly.
- Previous auditor not disclosed: Required in casual vacancy scenarios but frequently omitted.
A rejected filing still counts as not filed from the compliance deadline perspective. If the rejection pushes the actual accepted filing past 15 days, late fees and daily penalties apply to the entire period.
Key Points to Remember
- Form ADT-1 is mandatory for all company types, private, public, listed, unlisted, and OPC.
- The company is responsible for filing, not the auditor.
- The form must be filed even when an auditor is appointed to fill a casual vacancy.
- Filing must be completed within 15 days with no grace period.
- Both the company and its directors are exposed to daily penalties for late filing under the Companies Act, separate from the MCA portal’s additional fee structure.
- All filings are now on MCA V3. The V2 portal is no longer operational.
- Form ADT-1 is auto-approved on the portal, but rejection due to errors or missing documents means the process restarts, often past the deadline.
The Simplest Way to Avoid Problems
Form ADT-1 is not complicated, but it is time-sensitive. The 15-day window after the AGM, combined with the need to collect board resolutions, auditor consent letters, Section 141 certificates, and appointment letters, all properly signed, leaves little room for last-minute effort.
The practical advice is straightforward: begin collecting the required documents before the AGM, not after. The auditor should be informed of the impending appointment before the AGM so they can prepare their consent letter and Section 141 certificate in advance. Once the AGM concludes and the appointment is formalised, the documentation is ready and the filing can be completed within a day or two, well within the 15-day window.
Companies that treat ADT-1 as something to be handled at leisure after the AGM are the ones that end up paying penalties that dwarf the original filing fee.
