Form ADT-1 — Auditor Appointment Filing, Due Date After a 30 September AGM, and Who Must File (2026)

Every year a large number of companies hold their AGM on or close to 30 September, appoint or reappoint the statutory auditor in that meeting, and then lose track of the one-page form that has to follow. Form ADT-1 is small, cheap and quick — and it is one of the most commonly missed ROC filings, partly because it is not due every year. Here is when it applies, the exact deadline after a 30 September 2026 AGM, and what late filing costs. Position as on 14 October 2026.

Short answer

Short answer: when a company appoints or reappoints its statutory auditor at a general meeting, it must file Form ADT-1 with the Registrar of Companies within 15 days of that meeting, under Section 139(1) of the Companies Act, 2013 and Rule 4(2) of the Companies (Audit and Auditors) Rules, 2014. For an AGM held on 30 September 2026, file by 14 October 2026: some practitioners count the deadline to 15 October, but 14 October satisfies both readings. ADT-1 is filed once per appointment — normally once in five years — not every year.

Who must file ADT-1 this year

ADT-1 follows the appointment, not the calendar. In the 2026 AGM season, these are the companies that need it:

Listed companies and the classes prescribed under Rule 5 — unlisted public companies with paid-up capital of ₹10 crore or more, private companies with paid-up capital of ₹50 crore or more, and companies with borrowings from banks, financial institutions or public deposits of ₹50 crore or more — must also rotate auditors: one five-year term for an individual auditor and two consecutive terms for a firm. A rotation-driven change of auditor is a new appointment, so it needs ADT-1 too.

Not every year — the five-year term

Under Section 139(1), an auditor appointed at an AGM holds office from the conclusion of that meeting until the conclusion of the sixth AGM — a five-year term. Until 2018 the appointment also had to be ratified by members at every AGM, and many companies filed ADT-1 each year as a result. That ratification requirement was omitted with effect from 7 May 2018. Since then, a company files ADT-1 when an auditor is appointed or reappointed — not for the years in between.

The due date: 14 or 15 October?

The rule says the notice must be filed "within a period of fifteen days of the meeting in which the auditor is appointed". Practitioners count this two ways. Counting the meeting day as day one — the reading many professionals and fee calculators use for the MCA system — a 30 September AGM gives a last date of 14 October. Excluding the meeting day gives 15 October. Since filing by the earlier date is compliant under both readings and the form takes minutes, the earlier date is the one to work to.

If the AGM was adjourned, or the auditor was appointed at an extraordinary general meeting, the 15 days run from the meeting at which the appointment was actually made.

First auditors and casual vacancies

A new company's first auditor is appointed by the board within 30 days of incorporation (or, failing that, by members within 90 days) under Section 139(6), and holds office until the first AGM. Rule 4(2) refers to appointments under Section 139(1), so for years first-auditor filings were treated as optional. The revised Form ADT-1, notified by G.S.R. 359(E) dated 30 May 2025 and in force from 14 July 2025, now includes "first auditor" as a nature of appointment. Rule 4(2) itself was not reworded, so whether filing is legally mandatory is debated — but the form now provides for it and filing within 15 days of the board meeting is the prudent course.

A casual vacancy — death, disqualification or resignation of the auditor — is filled by the board within 30 days under Section 139(8); where the vacancy arose from resignation, the board's appointment must also be approved by members within three months. ADT-1 is filed for the new appointment. The outgoing auditor who resigns files Form ADT-3 separately.

Documents and filing on MCA V3

1. Before the meeting: obtain the auditor's written consent and the certificate of eligibility under Sections 139 and 141 — the appointment cannot be validly made without them.
2. At the meeting: pass the resolution appointing the auditor, with the term (normally from this AGM to the conclusion of the sixth AGM) and the remuneration basis.
3. After the meeting: send the auditor a written intimation of the appointment — the rule requires the company to inform the auditor as well as the Registrar.
4. File ADT-1 on the MCA V3 portal with the auditor's details (membership number or firm registration number, PAN, address), the date of appointment and the period, and attach the resolution, the consent and eligibility certificate, and the intimation letter.
5. Sign with the digital signature of an authorised director or the company secretary, pay the fee, and keep the SRN — the AOC-4 for the year asks for the ADT-1 SRN.

Late fee and penalty

The normal government fee depends on the company's nominal share capital, from ₹200 for capital below ₹1 lakh (and for companies without share capital) up to ₹600 for ₹1 crore and above. Filing late multiplies it:

The additional fee is modest — at most ₹7,200 on a ₹600 base. The larger exposure is separate: not giving notice of the appointment is a contravention of Section 139, and Section 147 provides for amounts of ₹25,000 to ₹5,00,000 on the company and ₹10,000 to ₹1,00,000 on each officer in default. An unfiled ADT-1 also leaves the AOC-4 without the SRN it asks for, so one missed form tends to complicate the next.