The cost audit rules use four forms with very similar names, and they are constantly confused. Only two of them are filed with the MCA. Here is what each one is, who is responsible for it, and when it is due for a company with a 31 March year-end.
| Form | What it is | Prepared by | Filed with | Due date |
|---|---|---|---|---|
| CRA-1 | The format of cost records the company must keep | The company | Not filed. Kept in the books. | Maintained through the year |
| CRA-2 | Intimation of the cost auditor's appointment | The company | MCA | Within 30 days of the Board meeting, and in any case within 180 days of the year starting (27 September) |
| CRA-3 | The cost audit report and its annexures | The cost auditor | The Board of Directors | Within 180 days of year-end (27 September) |
| CRA-4 | The cost audit report in XBRL | The company | MCA | Within 30 days of receiving CRA-3. For FY 2025-26, no additional fee up to 31 December 2026. |
CRA-1: the records, not a filing
CRA-1 sets out what a company's cost records must contain: material, labour, overheads, utilities, production quantities and the reconciliation with the financial accounts. It applies to companies in the industries listed in the Rules with turnover of ₹35 crore or more. Many companies keep cost records without needing a cost audit, so CRA-1 can apply even when CRA-2, CRA-3 and CRA-4 do not.
CRA-2: appointing the cost auditor
The Board appoints the cost auditor on the Audit Committee's recommendation, and the members ratify the fee. CRA-2 tells the MCA about it. The appointment must be made within 180 days of the start of the year, so for FY 2026-27 the outer date was 27 September 2026. A fresh CRA-2 is needed every year, even if the same auditor continues.
CRA-3: the report to the Board
The cost auditor signs CRA-3 and sends it to the Board within 180 days of the year-end. For FY 2025-26 that was 27 September 2026. The Board considers it and the company then has 30 days to file it.
CRA-4: filing the report with the MCA
CRA-4 is the CRA-3 report converted into XBRL and filed by the company. The normal limit is 30 days from receipt. For FY 2025-26, MCA General Circular 06/2026 (27 October 2026) allows CRA-4 to be filed without additional fee up to 31 December 2026. After that date, additional fees run from the original due date.
Common mistakes
- Filing CRA-2 once and forgetting it. It is an annual filing.
- Treating CRA-3 as the filing. CRA-3 only reaches the Board. The MCA sees nothing until CRA-4 is filed.
- Appointing the statutory auditor as cost auditor. The law does not allow it.
- Waiting for the XBRL conversion until the last week. XBRL validation errors are common and take time to fix.
Whether cost audit applies to you at all is covered in our note on cost audit applicability and CRA-4 due date.
Frequently asked questions
Is CRA-1 filed with the ROC?
No. CRA-1 is the format of cost records the company maintains. It is not filed with the MCA.
What is the due date of CRA-2?
Within 30 days of the Board meeting that appoints the cost auditor, and in any case within 180 days from the start of the financial year. For FY 2026-27 the outer date was 27 September 2026.
What is the difference between CRA-3 and CRA-4?
CRA-3 is the cost audit report the cost auditor gives to the Board. CRA-4 is the same report in XBRL that the company files with the MCA within 30 days of receiving it.
Has the CRA-4 due date been extended for FY 2025-26?
Yes. Under MCA General Circular 06/2026 dated 27 October 2026, CRA-4 for FY 2025-26 can be filed up to 31 December 2026 without additional fee.
Who can be appointed as cost auditor?
A Cost Accountant in practice or a firm of Cost Accountants. The company's statutory auditor cannot be its cost auditor.
How Vitt-Marg helps
We handle ROC, cost audit and income-tax compliance for companies and LLPs across Noida, Greater Noida, Ghaziabad and Delhi NCR. Send us your CIN or LLPIN and we will tell you what is pending, what it will cost, and file it before the next deadline.
General information, current as of 4 November 2026, not advice for a specific case. Due dates and fees change with MCA and CBDT notifications. Check with us before acting on it.