Cost Records & Audit Reference Guide

Plain-language guide to the Companies (Cost Records and Audit) Rules 2014 — who needs to comply, when, and what happens if you don't.

Who Must Maintain Cost Records?

Under Rule 3, every company governed by the Companies Act 2013 that is engaged in the production of goods or provision of services specified in the Annexure — and whose aggregate net worth is ₹1 crore or more OR whose turnover from the relevant products/services is ₹35 crore or more — must maintain cost records in accordance with the Cost Accounting Standards.

Key point: Cost record maintenance (Rule 3) is a DIFFERENT and BROADER obligation than cost audit (Rule 4). Many companies that are not subject to cost audit are still required to maintain cost records.

Table A — Regulated Sectors (Threshold: ₹35 Cr Net Turnover)

These are sectors where the government directly controls prices, subsidies, or tariffs. Cost records are the basis for regulatory decisions.

#Sector / ProductRegulatory Body
1Petroleum & Natural Gas (Crude oil refining, petroleum products)MoPNG / PPAC
2Drugs & Pharmaceuticals (Bulk drugs, formulations)NPPA / CDSCO
3Fertilisers (Nitrogenous, phosphatic, potassic)Department of Fertilisers
4Sugar & Khandsari SugarDepartment of Food & PD
5Electricity (Generation, Transmission, Distribution)CERC / SERC
6Telecommunications (Basic & mobile telephony, ISP)TRAI / DoT
7Jute & Jute ProductsMinistry of Textiles

Table B — Non-Regulated Sectors (Threshold: ₹35 Cr Net Turnover)

These sectors operate in competitive markets but are significant from a national economic perspective.

#Sector / Product
1Steel & Iron Products (all categories)
2Cement, Cement Products, and Clinker
3Aluminium & Aluminium Products
4Tyres & Tubes (Rubber-based automotive products)
5Paper & Paperboard
6Textiles (Cotton yarn, synthetic, woven fabrics)
7Chemicals, Pesticides & Dyes
8Automobiles & Auto Parts
9Mining & Minerals
10Railway Wagons, Coaches, Locomotives
11Rubber & Allied Products
12And 20+ more sectors…

Who Must Undergo Cost Audit?

Rule 4 mandates that companies in the above sectors ALSO undergo a statutory cost audit if their net turnover exceeds the specified thresholds. Cost audit is conducted by a registered Cost Auditor (CMA) appointed by the Board of Directors.

Regulated Sectors (Table A)

Threshold: Net turnover from regulated products ≥ ₹50 Crore in the immediately preceding financial year

Companies in Petroleum, Pharma, Fertilisers, Sugar, Power, Telecom sectors meeting this threshold must mandatorily appoint a registered Cost Auditor.

Non-Regulated Sectors (Table B)

Threshold: Net turnover from non-regulated products ≥ ₹100 Crore in the immediately preceding financial year

Steel, Cement, Automobiles, Textiles, Paper, and other Table B sector companies meeting this threshold require cost audit.

Key Compliance Deadlines

ActivityFormDeadline
Cost Auditor Appointment (Board Resolution)Within 180 days of start of FY (by 30 Sep for April-March FY)
Intimation of Appointment to MCACRA-2Within 30 days of Board resolution
Cost Audit Report to Company's BoardCRA-3Within 180 days of FY end (by 30 Sep)
Filing of Cost Audit Report with MCACRA-4 (XBRL)Within 30 days of receipt by Board
Cost Records (maintenance)Continuous — must be maintained throughout the year

Consequences of Non-Compliance

For the Company

Penalty up to ₹5 Lakh for failure to maintain cost records (Section 148(8)) or failure to file the cost audit report.

For Officers in Default

Penalty up to ₹1 Lakh for every officer in default — including the CFO, Managing Director, and Whole-time Director.

Protection: Companies that have appointed a registered Cost Auditor and are cooperating with the audit process are generally protected from penalties. Appoint a Cost Auditor today →

Frequently Asked Questions

Does a newly incorporated company need to maintain cost records in Year 1?

No. Applicability is based on turnover of the immediately preceding financial year. A company incorporated in Year 1 will check Year 1's turnover to determine if cost records are needed in Year 2. If turnover in Year 1 meets the threshold, cost records must be maintained from Year 2.

If cost audit is not applicable, do we still need cost records?

Yes. Rule 3 (cost records) and Rule 4 (cost audit) are separate obligations. A company can be required to maintain cost records (Rule 3) even if it is below the cost audit turnover threshold (Rule 4). Only companies in the specified industries that exceed the Rule 3 threshold must maintain records.

How is "net turnover" calculated for threshold purposes?

Net turnover = Gross turnover (from products/services in the specified industry) minus Indirect taxes (GST, excise duty collected on behalf of government). The threshold applies only to the net turnover from the specified products — not the company's total consolidated turnover.

What if a company crosses the threshold in one year but falls below it in the next?

Once a company meets the cost audit threshold, it must continue conducting cost audits in subsequent years, even if turnover subsequently falls below the threshold — unless the turnover falls below the threshold for 3 consecutive years. Companies should seek legal advice on exemption claims from the Central Government.

Can the same CA firm conduct both statutory financial audit and cost audit?

No. A cost audit must be conducted by a registered Cost Auditor — a Fellow or Associate Member of ICMAI (Institute of Cost Accountants of India) authorised to practise as a cost auditor. A Chartered Accountant (ICAI member) is NOT eligible to conduct a statutory cost audit under Section 148 of the Companies Act 2013.

Not Sure If You Need a Cost Audit?

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