Final Guidance Note on G.S.R. 371(E) | Effective 14th July 2025
Issued under the Companies (Filing of Documents and Forms in XBRL) Amendment Rules, 2025
Executive Summary
The Ministry of Corporate Affairs (MCA), via Notification No. G.S.R. 371(E) dated 06.06.2025, has rolled out a significant digital compliance reform under the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Amendment Rules, 2025.
Effective 14th July 2025, companies filing Form AOC-4 XBRL must mandatorily:
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Disclose CSR details as per the updated XBRL taxonomy, and
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Attach a PDF copy of the signed financial statements, duly authenticated by the Board and the statutory auditor.
This amendment strengthens India's move toward digitally enforceable corporate accountability and builds capacity for real-time CSR analytics.
Legal Framework and Key Provisions
| Provision | Relevance |
|---|---|
| Section 137 of Companies Act, 2013 | Filing of financial statements with Registrar |
| Section 135 of Companies Act, 2013 | CSR obligations, disclosures, and governance |
| Rule 12 of Companies (Accounts) Rules, 2014 | Filing of financial statements in XBRL format for select class |
| 2025 Amendment | Substitutes content of AOC-4 XBRL form schema |
Key Changes at a Glance
| Parameter | Earlier Position | New Requirement (From 14.07.2025) |
|---|---|---|
| CSR Disclosure | Not included in AOC-4 XBRL | Mandatory XBRL tagging for CSR fields |
| Attachment of Signed Financials | Not required | Compulsory PDF attachment of duly signed financials |
| Form Schema | Existing XBRL version | New MCA-approved taxonomy (2025 schema) |
| Responsibility for Filing | Company Secretary (if appointed) | CFO / Finance Head / Authorized Director |
Why This Matters – Strategic & Compliance Insights
1. Enforcement-Ready Data Compliance
The inclusion of signed PDFs and CSR fields ensures that e-filings are:
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Legally reliable and ready for prosecution if fraud is detected
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Suitable for real-time tracking of CSR non-compliance or misreporting
2. Strengthening Board Accountability
By mandating signed financials, MCA affirms that:
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Filing is not a back-office task but a board-level statutory responsibility
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Falsified or provisional accounts cannot be used for statutory filings
3. CSR Disclosures Become Digitally Traceable
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CSR compliance, unspent funds, and activity reporting now visible to regulators at a data-tag level, enabling macro-level ESG surveillance.
Standard Operating Procedure (SOP): Filing AOC-4 XBRL (Effective 14.07.2025)
Pre-Filing Preparation
| Step | Action | Responsibility |
|---|---|---|
| 1 | Update to the latest MCA XBRL taxonomy (2025 version) | XBRL Consultant / IT |
| 2 | Confirm CSR applicability and compute obligations | CFO / Finance Head |
| 3 | Finalise financial statements and have them signed by Board + Auditor | CFO / Auditor |
| 4 | Generate a PDF copy of signed financials for attachment | Finance Team |
E-Filing Process
| Step | Action | Responsibility |
|---|---|---|
| 5 | Populate the AOC-4 XBRL form using updated taxonomy | XBRL Consultant / CFO |
| 6 | Tag CSR data accurately in the machine-readable fields | CFO / Compliance Officer |
| 7 | Attach the signed financials (PDF) to the form | Filing Officer |
| 8 | Run Pre-Scrutiny validation on MCA portal | Compliance Officer |
| 9 | File AOC-4 XBRL using DSC of authorised signatory | CFO / Director |
Post-Filing Compliance
| Step | Action | Responsibility |
|---|---|---|
| 10 | Archive SRN, acknowledgment, and filing records | Records Department |
| 11 | Circulate signed financials at AGM as per Section 136 | CFO / Board |
| 12 | Update internal compliance trackers for next filing cycle | Internal Audit / CFO |
Quick Filing Checklist (Ready-to-Use)
✅ Updated XBRL utility installed with 2025 taxonomy
✅ CSR disclosures tagged appropriately (if applicable)
✅ PDF of signed Balance Sheet, P&L, Auditor’s Report ready
✅ DSCs of CFO/Director authorised for MCA filing
✅ Pre-scrutiny passed without technical errors
✅ MCA acknowledgment and SRN archived
Penalties & Non-Compliance Consequences
| Default Scenario | Relevant Law | Penal Consequence |
|---|---|---|
| CSR fields left blank or not tagged | Section 135, Rule 12 | Form may be rejected; scrutiny or show-cause possible |
| Signed PDF not attached | Section 134, Rule 12 | Treated as invalid return; re-filing & late fee risk |
| Filing delayed beyond AGM+30 days | Section 137(3) | ₹1,000/day up to ₹10 lakh (company) + ₹5 lakh (officer) |
| Filing with old schema or errors | MCA System validation | Technical rejection on upload |
Immediate Action Plan for Companies
✔ Review CSR applicability & track financial thresholds
✔ Coordinate with XBRL vendors to update software tools
✔ Conduct internal audit of financial statement sign-off processes
✔ Schedule filing calendar in advance of AGM timelines
✔ Sensitize board members and CFOs on new accountability norms
Frequently Asked Questions (FAQs)
Q1. We are not covered under CSR – is the new AOC-4 XBRL still applicable?
✅ Yes. Even if CSR is not applicable, the updated form must be filed with proper tagging (e.g., “Not Applicable” fields must be tagged accordingly).
Q2. Can we attach unsigned or scanned draft financials temporarily?
❌ No. Filing unsigned or draft PDFs violates Section 134 and may render the form invalid. Attach only final, signed financial statements.
Q3. Has the form AOC-4 XBRL been replaced?
✔ Not in name, but in content — the existing AOC-4 XBRL form schema has been substituted. The e-form name remains unchanged.
Q4. Can a company without a Company Secretary file this form?
✔ Yes. Where no CS is appointed, the form can be filed by the CFO, Finance Head, or Director, duly authorised.
Closing Note
This update signals MCA's deepening intent to ensure that every statutory filing is:
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Authentic (via signed PDFs)
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Digitally scrutable (via XBRL analytics), and
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Board-approved (not left to consultants alone)
Companies must proactively align internal processes to this elevated compliance standard.
"E-governance is no longer just about ease of doing business — it’s about the quality and integrity of business disclosures."
- Contributed by Shubham Patel
CA Finalist at Sandeep Ahuja & Co.