NFRA-2 sheet for CA firms: which audit clients put you in scope, and what to collect before the 30 November 2026 annual return
What you get: a finished NFRA-2 readiness sheet in three tabs: an In-scope test tab that checks each audit client against the rule 3 classes, a Report log tab with one row per audit report you signed in the reporting period and every field the form asks for, and a Firm details tab for partners, employees, network, reviews, resignations and the quality control statement, plus a made-up example and a partner note.
Short answer (checked 27 Oct 2026): under rule 5 of the National Financial Reporting Authority Rules, 2018 (as amended by G.S.R. 636(E), 5 September 2019), every auditor of the companies and bodies corporate listed in rule 3 must file an annual return with NFRA on or before 30 November every year in Form NFRA-2. This year that is Monday 30 November 2026. NFRA's own guide says the return reports the audit reports signed during the reporting period of 1 April to 31 March. On that pattern, the 30 November 2026 return covers reports signed from 1 April 2025 to 31 March 2026, which in most cases means audits of FY 2024-25 accounts. The form is filed online on the NFRA-2 e-form portal (eformnfra2.nic.in).
Who has to file
NFRA's NFRA-2 guide lists the auditors of these classes (rule 5 read with rule 3):
| Class | Test |
|---|---|
| Listed companies | Securities listed on any stock exchange in India or outside India |
| Large unlisted public companies | Any one of: paid-up capital of not less than ₹500 crore, annual turnover of not less than ₹1,000 crore, or aggregate outstanding loans, debentures and deposits of not less than ₹500 crore |
| Specialised sectors and special Acts | Insurance companies, banking companies, companies generating or supplying electricity, companies governed by a special Act, and bodies corporate incorporated by an Act as in section 1(4)(b) to (f) of the Companies Act, 2013 |
| Central Government reference | Any company, body corporate or person referred by the Central Government in public interest |
| Foreign subsidiary or associate | A body corporate incorporated outside India that is a subsidiary or associate of any of the above, where its net worth or income exceeds 20% of the consolidated net worth or income |
Most small and mid-size CA firms audit none of these, and then nothing is due. The ones that get caught are firms with one in-scope client: a small company listed on an SME exchange, a large unlisted public company, or a foreign subsidiary of one.
Tab "In-scope test": one row per audit client
| Column | What to write |
|---|---|
| A. Client ref | Your internal reference |
| B. Listed (India or abroad)? | Yes / No |
| C. Public company, unlisted? | Yes / No |
| D. Paid-up capital (₹ crore) | From the audited balance sheet |
| E. Turnover (₹ crore) | Same |
| F. Loans + debentures + deposits outstanding (₹ crore) | Same |
| G. Sector or special Act? | Insurance, banking, electricity, special Act, or none |
| H. In scope? | =IF(OR(B2="Yes",AND(C2="Yes",OR(D2>=500,E2>=1000,F2>=500)),G2<>"none"),"In scope","Not in scope") |
| I. On NFRA's provisional company list? | Look the client up in NFRA's "List of Companies (Provisional)" on nfra.gov.in under NFRA Domain |
| J. Report signed 1 Apr 2025 to 31 Mar 2026? | Yes / No |
| K. Goes in this NFRA-2? | =IF(AND(OR(H2="In scope",I2="Yes"),J2="Yes"),"Report it","No") |
Working rule: the formula in H is a first filter, not the legal test. Check rule 3 itself for the period that applies (the thresholds are read on the figures the rule refers to), and treat a client that appears in NFRA's provisional list but fails your formula as a question for the engagement partner, not a "No". Foreign subsidiaries and Central Government references are not in the formula; add them by hand.
Tab "Report log": one row per in-scope audit report
These are the fields Form NFRA-2 asks for in part 4, so collecting them now saves the last-week scramble:
- Name of the company or body corporate, and its CIN or PAN (FCRN or identity number for a foreign body)
- Global Location Number, if any
- Class in which it falls (listed, unlisted under rule 3(1)(b), insurance, banking, electricity, special Act, Act-incorporated body, Central Government reference)
- Registered address
- Date of the audit report
- Name and registration number of the engagement partner and of the engagement quality review partner
- Whether the report was modified; any unfavourable or qualified findings; any matter on which no opinion could be expressed
- Fees and expenses received from the client, split into statutory audit, tax audit and other taxation, attestation and certification, non-audit services, and out-of-pocket expenses; plus the conversion rate if not received in rupees
- For a foreign subsidiary or associate: auditing and accounting standards followed, period covered, the parent's CIN or PAN and name, consolidated income and net worth, the subsidiary's own income and net worth, and the parent's audit firm
Status column: =IF(COUNTBLANK(B2:P2)=0,"Ready","Missing "&COUNTBLANK(B2:P2)&" fields"), with B to P being the columns you keep for the fields above.
Tab "Firm details": once per firm
- Category (individual, firm, Indian LLP, foreign LLP), LLPIN or firm registration number, PAN, ICAI registration, registered and mailing address, phone, website
- Quality control or peer reviews by any regulator: name, date, validity, rating and any adverse remarks
- Network membership or affiliation, and whether the network is registered with ICAI (with the number)
- Number and details of partners, and number of employees
- Disciplinary or other proceedings against the firm, a partner or an employee, and whether a final order was passed
- Resignations from any in-scope client, and any withdrawn audit report, in the past three years
- A statement of the firm's quality control policies and procedures for its audit practice in the period
- Consent to co-operate with NFRA information requests, and the signature of a partner or authorised officer
A 2019 FAQ by Vinod Kothari & Co. also lists a user login on the NFRA portal and a Digital Signature Certificate of the user. Check the DSC's expiry in the first week, not on 30 November.
Plan for the next five weeks
| By | Do |
|---|---|
| Fri 30 Oct | Fill the In-scope test for every company audit client. Most firms stop here with "nothing to file". |
| Fri 6 Nov | For in-scope clients, pull audit report dates, partner and EQR partner numbers, and the fee split from billing. Expect slow replies around Deepavali (8 Nov). |
| Fri 13 Nov | Complete the Firm details tab; check DSC validity and the e-form login. |
| Fri 20 Nov | Partner review of the whole sheet, especially modified reports and the quality control statement. |
| Fri 27 Nov | File. 30 November 2026 is a Monday: aim for the Friday before. |
Why it matters: NFRA publishes provisional lists of audit firms that have not filed or filed incomplete NFRA-2 returns. The latest on its NFRA Domain page, for reporting period 2024-25, shows the position as on 15.08.2026. We do not quote a penalty amount here; check the current Companies Act text before you advise anyone on consequences.
Made-up example (not a real firm)
A four-partner firm audits 60 private companies and one unlisted public company with turnover of ₹1,150 crore. The In-scope test marks that one client "In scope". Its FY 2024-25 audit report was signed on 18 September 2025, inside 1 April 2025 to 31 March 2026, so the sheet shows "Report it". The Report log row is missing the EQR partner's registration number and the non-audit fee split, so status reads "Missing 2 fields". The firm also resigned from another in-scope client in 2024, which goes in the Firm details tab under resignations in the past three years.
Note to partners
"NFRA-2 for the reporting period 2025-26 is due by Monday 30 November 2026. Please confirm by [date] whether any of your audit clients is listed, an unlisted public company over ₹500 crore paid-up capital, ₹1,000 crore turnover or ₹500 crore borrowings, or in insurance, banking or electricity, and send the audit report dates and fee split for those clients."
Related guides
- November 2026 due-date chase list for CA firms
- Auditor rotation under section 139: five years, two terms, cooling-off
- ADT-3 auditor resignation: 30 days, section 140
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Sources
- NFRA: "NFRA-2 Annual Return: Know Why & How" (who must file, reporting period table, contents)
- MCA notification G.S.R. 636(E), 5 September 2019: NFRA (Amendment) Rules, 2019, rule 5 and Form NFRA-2
- NFRA Domain page: provisional list of companies and of firms that have not filed NFRA-2
- PIB: NFRA publishes list of auditors who have not filed NFRA-2 (due 30 November every year)
- Vinod Kothari & Co.: FAQs on NFRA (documents needed to file, DSC)
This sheet is a working aid, not professional advice. Check the NFRA Rules, 2018 and the NFRA-2 e-form portal before you rely on it. Checked on 27 October 2026. Spot an error? Write to mininglife7@gmail.com.
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