Registered Valuer Under Rule 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.
The disclosure does not ask what the valuation was. It asks who produced it — and it requires an answer even when the answer is "not a registered valuer".
The three disclosures
| Asset | Trigger | Disclosure |
|---|---|---|
| Investment property | Fair value as measured for disclosure purposes in the financial statements | Whether the fair value is based on the valuation by a registered valuer as defined under rule 2 of the Companies (Registered Valuers and Valuation) Rules, 2017 |
| Property, plant and equipment, including right-of-use assets | Where the company has revalued them | Whether the revaluation is based on the valuation by a registered valuer as so defined |
| Intangible assets | Where the company has revalued them | Whether the revaluation is based on the valuation by a registered valuer as so defined |
The negative answer is also a disclosure
In case the company has not used a registered valuer for such fair value or revaluation purposes, the fact needs to be disclosed in the financial statements.
This is what makes the requirement operative. A disclosure that only had to be made when a registered valuer was engaged would let silence do the work of an assertion. Here silence is not available — the company states one way or the other.
Under Ind AS 40 as applied in India, investment property is carried at cost; fair value is disclosed, not recognised. So the fair value figure never enters the balance sheet or the results.
The registered valuer disclosure applies to it anyway — and the text is careful to say "only as measured for the purpose of disclosure in the financial statements".
The reasoning is that a disclosed fair value is used by readers exactly as a recognised one would be: to assess how far carrying amount departs from value. A number that influences that assessment carries the same need for provenance whether or not it changes the totals.
For PPE, right-of-use assets and intangibles the position is the reverse — a revaluation does change carrying amounts and feeds the revaluation surplus in OCI, so the provenance of the number affects reported equity directly.
What "registered valuer" means here
The definition is imported from rule 2 of the Companies (Registered Valuers and Valuation) Rules, 2017 in all three disclosures. It is not a general reference to a professional valuation — a valuation by an expert who is not registered under those Rules produces the "not used a registered valuer" answer.
Right-of-use assets are inside the PPE disclosure
The PPE requirement expressly reads "including Right-of-Use Assets". Under Ind AS 116 a lessee's right-of-use assets may be revalued where the revaluation model is applied to the underlying class of PPE, and the registered valuer disclosure follows them.
Common mistakes
- Making the disclosure only when a registered valuer was engaged.
- Treating an unregistered professional valuation as satisfying the rule 2 test.
- Omitting right-of-use assets from the PPE revaluation disclosure.
- Skipping the investment property disclosure because the fair value is not recognised.