Group Disclosures explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Eighteen new disclosures arrived on 24 March 2021. At the consolidated level they sort into three groups, and knowing which is which is most of the work.
Group disclosures always required at CFS level
| Requirement | How it applies to the group |
|---|---|
| Shareholding of promoters | Disclosed at CFS level. Generally the promoter would be the same for CFS level and standalone level. |
| Trade payables ageing schedule | Disclosed at CFS level after applying the principles of consolidation. |
| Trade receivables ageing schedule | Prepared at CFS level after applying the principles of consolidation. |
| Revaluation of PPE | Where done at CFS level or for any group entity: name of the entity in which revaluation is done; type and nature of PPE revalued; whether the revaluation is based on the valuation as per the registered valuer. |
| Loans or advances — additional disclosures | Done at CFS level on similar lines as related party transactions are disclosed in CFS — parties to whom such loans or advances are provided are assessed at consolidated group level. |
| Details of benami property held | Name of each subsidiary / group entity that has such property. Proceedings against an associate company are disclosed if material to the group. |
| Wilful defaulter | Name of each subsidiary / group entity declared a wilful defaulter. Wilful default by an associate company is disclosed if material to the group. |
| Relationship with struck off companies | Name of each subsidiary / group entity with such a relationship. If any subsidiary is itself on the struck off company list, the company should indicate that fact. An associate's relationship is disclosed if the transaction is material to the group. |
| Compliance with number of layers of companies | The company should disclose this fact of compliance for each entity in its group. |
| Undisclosed income | Name of each subsidiary / group entity having undisclosed income; an associate's undisclosed income if material to the group. |
Five of these group disclosures follow an identical two-tier pattern — benami property, wilful defaulter, struck off companies, and undisclosed income.
For subsidiaries and group entities, the requirement is to name each one, unconditionally. For an associate company as defined under the Act, the requirement applies only where the matter is material to the group.
The distinction tracks control. A subsidiary's conduct is the group's conduct and the parent has the information; an associate is merely influenced, and the parent's access to its affairs is limited. Requiring unconditional naming there would demand information the parent may not be able to obtain.
Group disclosures made only if material — the 10% filter
The following are disclosed at CFS level only if material in nature, i.e. more than 10% of the respective balance sheet or financial statement line item in the CFS:
- Capital work-in-progress ageing schedule / completion schedule;
- Intangible assets under development ageing schedule / completion schedule;
- Security of current assets against borrowings;
- Compliance with approved Scheme(s) of Arrangements;
- Utilization of borrowed funds and share premium — provided after applying principles of consolidation, i.e. for funds borrowed or invested outside the group;
- Details of crypto currency or virtual currency.
Not relevant at CFS level
- Title deeds of immovable property not held in the name of the company;
- Registration of charges or satisfaction with the Registrar of Companies;
- Analytical ratios.
All three are entity-level facts. Title deeds and charge registrations attach to a named company, and the eleven analytical ratios are calibrated to a single entity's standalone figures — which is why they survive in full in the standalone accounts and disappear from the group disclosures.
Common mistakes
- Preparing the ageing schedules without eliminating intra-group balances.
- Naming associates unconditionally instead of applying the materiality test.
- Presenting the analytical ratios in the consolidated financial statements.
- Including funds borrowed or invested within the group in the utilization disclosure.