The Ministry of Corporate Affairs (MCA), on 25 February 2020, announced Companies (Auditor’s Report) Order 2020 (CARO, 2020) in a conference with NFRA (National Financial Reporting Authority). This CARO 2020 has vetoed CARO 2016. 

CARO report 2020 is administered with enhanced revelation by the auditors. It is depicted in their audit report based on recommendations implemented by the Ministry of Corporate Affairs (MCA) committee. In this blog, we are going to discuss the applicability of CARO in audits.

What Is the Applicability of the CARO Report?

CARO 2020 is the exact same as CARO 2016. It is relevant to all the institutions to which CARO 2016 was applicable. Nonetheless, it is not pertinent to consolidate financial statements such as CARO in Audit Report 2016. 

The Ministry of Corporate Affairs has shelved the applicability of CARO 2020 from the financial year beginning from 1st April 2021 instead of 1st April 2020 as per its alert of 17th December 2020. It was implemented to ease the burden on corporations, and their auditors for the year 2020-21 amid the coronavirus disease (Covid-19).  

Applicability Of CARO in Audit Report: Matters

  • Applicability of the CARO in Audit Report is on the following conditions:
  • Details of tangible, and intangible assets.
  • Details of guarantees, investments, advances, or loans granted or security.
  • Brief of working capital and inventory.
  • Internal Audit System
  • Default in repayment of borrowings
  • Compliance with transactions with related parties
  • Compliance in consideration of deposits accepted.
  • Compliance related to the loan to directors
  • Funds raised and utilized.
  • Unrecorded income
  • Maintenance of costing records
  • Deposit of statutory liabilities 
  • No-cash dealings with directors
  • Funds raised by a company by way of an IPO (Initial Public Offer),
  • Registration takes place in Section 45 IA of the RBI Act
  • Cash losses
  • The company does any fraud.
  • Exchange of funds mentioned under Schedule VII of the Companies Act, 2013
  • Resignation of statutory auditors
  • Educational Qualifications or conflicting auditor reports in other group companies.
  • Material uncertainty in encountering liabilities

The CARO Auditor Report Order is meant to state the reasons for its unfavorable or qualified opinion. Moreover, if the auditor is unable to state any opinion, then in the report he needs to indicate the reason for the same.

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Applicability Of CARO Report: Companies

CARO in Audit 2020 applies to all companies including foreign companies, except for the mentioned ones:

  • OPC (One-person company) as depicted in clause (62) of section 2 of the Companies Act 2013.
  • A private firm that is not a subsidiary or holding of a public company.
  • Banking organizations as specified under clause (c) of Section 5 of the Banking Regulation Act 1949.
  • Small companies (Companies with paid-up capital lower than or equivalent to Rs. 50 lakhs, and with last sale less than or equivalent to Rs. 10 crores)
  • Companies enlisted for charitable purposes under Section 8 of the Companies Act.
  • Insurance companies, as stated under the Insurance Act 1938.
  • Private enterprises with gross revenue or receipts (including income from discontinuing functions) of more than Rs. 10 crores as per the financial records during the financial year.
  • Private firms with paid-up share capital and surplus and reserves not exceeding more than Rs. 1 crore as of the balance sheet date, i.e., at the end of the financial year.
  • A private institution that does not comprise entire borrowings of more than Rs. 1 crore from any financial institution, such as banks, at any point of time during the financial year. 

Content To Be Mentioned in the CARO Report

  • Property, Plant, and Equipment

This involves the following matters for the applicability of the CARO report-

  • Adequacy of Records
  • Physical verification
  • Revaluation of Plant, Property, and Equipment

  • Proceedings for holding Illegal Property
  • Inventories

Physical verification of stock is the duty of the management, which should affirm all material goods at least once a year and more frequently in pertinent cases. The periodicity of the physical verification of inventories relies upon the nature of stocks, their site, and the feasibility of conducting a physical verification. 

  • Investments, Guarantee / Security, Loans, or Advances

It indicates if during the year the business has granted loans, stood guarantee, or security to any other entity [not relevant to firms whose principal business is to grant loans].

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Final Thoughts

CARO Report 2020 is applicable for the audits following the financial years 2021-2022 onwards. Not only that, but the applicability of the CARO in Audit is also conditional on the type of companies.

Since there are certain kinds of organizations to which this aspect is not applicable. For example- banking and insurance companies. Some extra clauses are added as well as modified. 

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