Call For Business Enquiries : +91 9819 000 511 / +91 9821 83 26 83 / +91 9819 000 445

Form ADT-1 Auditor Appointment Filing (Sec 139) | N D Savla
Company Compliance

Form ADT-1 Filing in India
Auditor Appointment Under Section 139, Companies Act 2013

Resolution drafting, auditor consent and eligibility certificate, and MCA portal filing within the 15-day window — the complete ADT-1 engagement handled alongside the wider audit and annual filing cycle.

Part of our Company Compliance practice: Company Compliance Form ADT-3 Filing Form AOC-4 Filing Annual Filings

What Is Form ADT-1 Under the Companies Act, 2013?

Form ADT-1 is the statutory intimation a company files with the Registrar of Companies (ROC) to notify the appointment or reappointment of its statutory auditor, under Section 139 of the Companies Act, 2013. Appointing an auditor is a mandatory governance step for every company, and the appointment is not complete on the Registrar's record until Form ADT-1 is filed. Whether it is the first auditor after incorporation or a reappointment at the annual general meeting, timely filing keeps the company compliant and penalty-free.

Form ADT-1 is the prescribed electronic form through which a company informs the ROC that it has appointed or reappointed an auditor, as required by Section 139 read with Rule 4 of the Companies (Audit and Auditors) Rules, 2014. The obligation to file rests on the company, not on the auditor. Under the Companies (Audit and Auditors) Amendment Rules, 2025, effective 14 July 2025, filing Form ADT-1 is now mandatory even for the first auditor appointed by the board.

At N D Savla & Associates, our Mumbai Chartered Accountants handle the complete ADT-1 process — from drafting the board or AGM resolution and collecting the auditor's consent and eligibility certificate to filing the form on the MCA portal within the deadline. We manage it alongside the wider audit and assurance engagement so appointment and audit run as one seamless process.

Getting ADT-1 right is not just a formality. An unfiled or late intimation leaves the auditor's appointment unrecorded on the public register, invites a steeply rising additional fee, and can create questions during due diligence, bank funding, or a later audit. Treating it as a fixed 15-day task — done at the moment of appointment rather than weeks later — is the simplest way to keep the record clean.

When Is Form ADT-1 Required?

Form ADT-1 is required whenever an auditor is appointed or reappointed. Every company — regardless of size, listing status, or activity — must file it within 15 days of the appointment event:

First Auditor After Incorporation

Appointment of the first auditor by the board of a newly incorporated company — mandatory under the 2025 Amendment Rules, 15 days from the first board meeting.

Appointment or Reappointment at AGM

Appointment of an auditor for a term, or reappointment, at the annual general meeting — the most common trigger for existing companies.

Filling a Casual Vacancy

Appointment of an auditor to fill a vacancy caused by resignation, death, or disqualification — the incoming auditor's appointment must be intimated within 15 days.

Auditor Rotation

Where mandatory rotation under Section 139(2) requires a different auditor, the incoming auditor's appointment triggers a fresh ADT-1 filing.

Private, Public & OPC

Applies broadly regardless of company type — private limited, public limited, One Person Companies, and newly incorporated companies all owe the same 15-day filing obligation.

Our Form ADT-1 Filing Services

Our ADT-1 engagement follows a clean, end-to-end sequence — resolution drafting, document assembly, form completion, and MCA portal filing — coordinated with the wider annual compliance cycle.

01

Resolution Drafting — Board & AGM

A valid appointment needs a correctly drafted resolution passed at the right meeting. We draft the board resolution (for first appointments and casual vacancies) or the AGM resolution (for five-year term appointments and reappointments), ensuring the wording matches the statutory requirement, names the auditor correctly, and records the period of appointment. A resolution that does not accurately reflect the appointment creates problems when the form is filed and when the record is later examined during due diligence or audit.
Companies Act 2013 – Section 139
02

Auditor Consent & Eligibility Certificate

ADT-1 cannot be filed without the auditor's written consent to the appointment and the auditor's certificate confirming eligibility and that the appointment is within the limits of Section 141. We coordinate with the appointed auditor to collect these documents in the correct form, check that the eligibility certificate addresses the Section 141 conditions specifically, and assemble them alongside the intimation letter copy for attachment. Missing or poorly worded attachments are the most common reason for a defective filing.
Companies Act 2013 – Section 141
03

Form ADT-1 Completion & MCA Portal Filing

We complete Form ADT-1 with all required details — whether the auditor is an individual or firm, the ICAI membership number or firm registration number (FRN), the auditor's PAN and address, the period of appointment, and outgoing auditor details where applicable. The form is then filed digitally on the MCA portal within the 15-day window, applying the correct fee. We track the appointment date and map the deadline from the day of appointment, treating it as a hard cut-off rather than an approximation.
MCA21 V3 Portal Filing
04

Auditor Tenure & Rotation Advisory

Understanding auditor tenure avoids missed filings. Under Section 139, a statutory auditor is generally appointed for five years and ADT-1 is filed at that appointment — not annually, since the Companies (Amendment) Act, 2017 removed annual ratification. For prescribed classes of companies subject to mandatory rotation under Section 139(2), we track the individual and firm term limits, identify the rotation year, and ensure the new appointment is filed correctly. The goal is a complete record with no unexplained gaps.
Companies Act 2013 – Section 139(2)
05

Coordination with AOC-4 & Annual Return

ADT-1 does not sit in isolation — it connects directly to the AOC-4 financial statement filing and the annual return (MGT-7). The auditor recorded in ADT-1 must be the same auditor whose report is attached to AOC-4, and any mismatch between the Registrar's record of the auditor and the AOC-4 attachment creates questions. We coordinate all three as part of one compliance engagement, so the auditor's appointment and the financial statements line up consistently on the public record.

Penalties for Late Filing of Form ADT-1

Late filing of ADT-1 attracts an additional fee that rises steeply with the length of the delay, charged as a multiple of the normal fee under the Companies (Registration Offices and Fees) Rules, 2014.

Delay in FilingAdditional Fee (multiple of normal fee)
Up to 30 days2 times the normal fee
31 to 60 days4 times the normal fee
61 to 90 days6 times the normal fee
91 to 180 days10 times the normal fee
More than 180 days12 times the normal fee
File within 15 days: The additional fee doubles quickly with delay — a filing more than 180 days late costs twelve times the normal fee. Beyond the additional fee, an unfiled ADT-1 leaves a gap on the company's compliance record that surfaces during due diligence, bank facility reviews, and subsequent audits.

Broader Company Compliance Services

Form ADT-1 is one piece of the annual compliance cycle. Our complete company compliance practice covers:

Common Questions on Form ADT-1

What is the due date for filing Form ADT-1?
Form ADT-1 must be filed within 15 days of the auditor's appointment or reappointment. For a new company, that is 15 days from the first board meeting at which the auditor is appointed — effectively around 45 days from incorporation, since the first board meeting must be held within 30 days. For existing companies, it is 15 days from the AGM at which the auditor is appointed or reappointed. For a casual vacancy, the 15-day clock runs from the date of appointment to fill the vacancy.
Who is responsible for filing Form ADT-1 — the company or the auditor?
The company is responsible for filing Form ADT-1. It is the company that intimates the ROC of the auditor's appointment. This is different from Form ADT-3, which is filed by the auditor when the auditor resigns. The obligation to file ADT-1 rests entirely with the company, and the penalty for non-filing also falls on the company.
Is Form ADT-1 required for the first auditor of a new company?
Yes. Under the Companies (Audit and Auditors) Amendment Rules, 2025, effective 14 July 2025, filing Form ADT-1 is mandatory even for the first auditor appointed by the board. Newly incorporated companies should file it within 15 days of the first board meeting at which the auditor is appointed. The earlier grey area on whether the first appointment required ADT-1 has been resolved — the obligation now applies clearly.
What documents must be attached to Form ADT-1?
The main attachments are the board or AGM resolution approving the appointment, the auditor's written consent to the appointment, the auditor's certificate confirming eligibility under Section 141, and a copy of the intimation letter sent to the auditor. A complete, accurate set of attachments is what gets ADT-1 filed cleanly on the first attempt. Missing any attachment is the most common cause of a defective or rejected filing.
What is the penalty for late filing of Form ADT-1?
Late filing attracts an additional fee charged as a multiple of the normal fee, rising with the delay — 2 times up to 30 days, 4 times for 31 to 60 days, 6 times for 61 to 90 days, 10 times for 91 to 180 days, and 12 times beyond 180 days. Filing within 15 days avoids these charges entirely. Beyond the fee, a gap in the ADT-1 record creates questions during due diligence and subsequent audits.
How is Form ADT-1 different from Form ADT-3?
ADT-1 and ADT-3 sit at opposite ends of the auditor relationship. ADT-1 is the company's intimation of an appointment or reappointment, filed within 15 days of appointment. ADT-3 is the auditor's notice of resignation, filed by the outgoing auditor within 30 days of resignation. They typically connect in sequence when an auditor change happens — the outgoing auditor files ADT-3, then the company appoints a new auditor and files ADT-1.

Appointing or reappointing your auditor? File ADT-1 the right way.

Talk to our Company Compliance team — resolution drafting, auditor consent, MCA portal filing, and coordination with AOC-4 and MGT-7 under one roof.

Get in Touch