CARO 2020: Top insights into the changing role of CFO and Auditor

CARO 2020 was introduced on February 25, 2020, and made effective for all the reports to be issued for the financial years commencing on or after April 1st, 2019. 

This publication highlights key takeaways for Auditors, CFO, and other senior management. 

Considering a very short time given for companies to comply with this Order, the implementation of this order is going to be an uphill battle for companies. When the companies have to look back certain policies that never existed in the last 11 months and comply the same in the next 1 month, it is likely that the application for this order may be deferred for few quarters.

The regulators have definitely given a thought for Small business and have exempted CARO 2020 for below private companies including certain specific categories of the company like banking, insurance, section 8 companies, and one person company:  

• Private companies excluding holding/subsidiary companies with paid-up capital of less than or equal to Fifty Lakhs Rupees and turnover less than Rupees two crores during previous Financial Year (Both conditions must be satisfied)
• Private companies having a paid-up capital and reserves and surplus not more than one crore rupees as on the balance sheet date and which does not have total borrowings exceeding one crore rupees from any bank or financial institution at any point of time during the financial year and which does not have a total revenue as disclosed in Scheduled III to the Companies Act (including revenue from discontinuing operations) higher than ten crore rupees during the financial year as per the financial statements (all three conditions must be satisfied). 
• Consolidated Financial statement has also been exempted except certain reporting related to Fraud reporting which must be included by the auditor for consolidated financial statements as well.

Below are in-depth analysis of our expert team related to certain key matters of CARO 2020:

• Intangible Assets: Similar to erstwhile reporting on Fixed Assets, the CARO 2020 requires management to maintain complete details about intangible assets. Although the order is currently silent on the details to be maintained, however, it will be expected to maintain details such as Name, in which process /business of the company it is being used, their useful life, cost involved in developing of acquiring and most importantly if the intangible assets are internally generated then how the accounting standard requirements related to capitalization of intangibles are adhered to. This may pose certain challenges to various start-up companies who have been capitalizing on certain intangible assets in their business. Management and auditor both have to be vigilant to ensure that the proper record of capitalization is maintained. Companies may consider adopting certain Project Management Software including an integrated Time Sheet and expense management tool to establish the authenticity of the amount capitalized.
• Immovable properties other than leased property: Auditors are required to report if the title deeds of all the immovable properties disclosed in the financial statements are held in the name of the company. This reporting may pose a significant business risk to real estate companies who have been reporting a significant amount of immoveable properties without the title deed in their name or otherwise. The auditors are also required to report whether any proceedings have been initiated or are pending against the company for holding any Benami property under the Benami Transactions (Prohibition) Act, 1988 (45 of 1988). 
• Reporting related to working capital loan: If the company has been sanctioned working capital loan in excess of rupee five crores on the basis of security of current assets, auditors will be required to report if various statements submitted by the companies to Bankers agree to their books of account or not. This may increase the work of the auditor who has been focusing on auditing numbers on an annual basis. They need to start focusing on quarterly numbers as well to ensure reporting for this clause. 
• Reporting related to loans, advances, and investments:  The auditors are required to report the aggregate amount of transactions during the year related to loans, advances, and investments, etc with group companies and other than group companies. Further, an auditor needs to report in respect of loans and advances in the nature of loans, whether the schedule of repayment of principal and payment of interest has been stipulated and whether the repayments or receipts are regular. In addition to above, certain other critical reporting related to loans and advances are required such as amount overdue, overdue more than 90 days, renewal of loans, granting of fresh loans to repay previous loans, any loan repayable on demand which may ultimately lead to identify potential risk on the balance sheet of the company. This reporting was primarily being asked from Bank Auditors till now and which seems to have extended to the company auditor under CARO 2020. 
• Reporting related to a loan taken: The auditors are required to disclose default in repayment of such loans and interest thereon or if the amount of loan was diverted for the purpose other than the purpose for which the loan was taken if the loan was taken for the use of group companies etc.  
• Share issue related compliances: CARO 2020 requires an auditor to report on whether the company has made any preferential allotment or private placement of shares or convertible debentures (fully, partially or optionally convertible) during the year and if so, whether the requirements of section 42 and section 62 of the Companies Act, 2013 have been complied with and the funds raised have been used for the purposes for which the funds were raised, if not, provide details in respect of amount involved and nature of non-compliance. It is critical to understand various compliances required under section 42 and 62  of the Companies Act, 2013. The Auditor must train themselves properly to be able to report under this clause. 

CARO 2020 reporting is going to be tougher for the auditor as well as companies. On the other hand, it will bring more transparency in the dealings of the companies. 

What else should businesses know about CARO 2020?

Author can be reached at vm@tya.co.in if any specific queries on this topic.