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NFRA-2 sheet for CA firms: which audit clients put you in scope, and what to collect before the 30 November 2026 annual return

Updated 27 Oct 2026 · Disclosure: the white-label calendar linked below is an Unadhi product (₹999/year). This guide is for information only, not professional advice.

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):

ClassTest
Listed companiesSecurities listed on any stock exchange in India or outside India
Large unlisted public companiesAny 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 ActsInsurance 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 referenceAny company, body corporate or person referred by the Central Government in public interest
Foreign subsidiary or associateA 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

ColumnWhat to write
A. Client refYour 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:

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

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

ByDo
Fri 30 OctFill the In-scope test for every company audit client. Most firms stop here with "nothing to file".
Fri 6 NovFor 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 NovComplete the Firm details tab; check DSC validity and the e-form login.
Fri 20 NovPartner review of the whole sheet, especially modified reports and the quality control statement.
Fri 27 NovFile. 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."

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Sources

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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