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★ 4.9/5 Rating📋 Form ADT-3⚡ Section 140(2)✨ CA / CS Assisted

Form ADT-3 —
Resignation of
Auditor Filing

When a statutory auditor resigns from a company, Form ADT-3 must be filed with the ROC within 30 days of resignation. The resigning auditor files this form — not the company. Late filing attracts a ₹50,000 minimum penalty on the auditor personally. TaxClue helps auditors and companies manage this filing correctly and on time.

📋 Section 140(2)📅 30-Day Deadline⚠️ ₹50,000 Min. Penalty👨‍💼 Auditor Files — Not Company

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Overview

What Is Form ADT-3 and Why Does It Exist?

Under Section 140(2) of the Companies Act, 2013, when a statutory auditor resigns from a company, they are legally required to file Form ADT-3 with the Registrar of Companies (ROC) within 30 days of the date of resignation. The form is filed by the auditor — not the company — and must include a statement indicating the reasons for resignation and whether there are any concerns about the company's affairs that the auditor believes the ROC or the Central Government should be aware of.

The requirement exists to ensure transparency — to prevent auditors from resigning silently when they discover financial irregularities, fraud, or governance failures. By mandating a public disclosure at the time of resignation, the law creates accountability for both the auditor (who must explain the reasons) and the company (whose issues become a matter of regulatory record).

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Critical: ADT-3 is the auditor's obligation — not the company's

If the auditor fails to file within 30 days, the auditor personally faces a minimum penalty of ₹50,000 and up to 5x the annual audit fees. This penalty applies to the CA firm / auditor — not to the company. Act immediately on resignation.

Who Files and When

ADT-3 Scenarios — When This Form Is Triggered

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Mid-Term Resignation

Auditor resigns before completing the appointed tenure — could be in year 1, 2, or 3 of a 5-year term. Must file ADT-3 within 30 days.

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Resignation Due to Concerns

Auditor resigns upon discovering financial irregularities, fraud, non-cooperation by management, or inability to obtain audit evidence. The ADT-3 statement of reasons becomes critical.

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Rotation / Change

Auditor resigns for legitimate business reasons — capacity constraints, conflict of interest, non-renewal of engagement letter, or client's voluntary request for a change. ADT-3 still mandatory within 30 days.

Late / Missed Filing

Auditor missed the 30-day window. ADT-3 can still be filed after the deadline — with additional government fee (₹100/day). But the Section 140(3) penalty applies regardless.

Step-by-Step Process

How TaxClue Handles ADT-3 Filing

1

Draft and Issue Resignation Letter to the Company

The resigning auditor prepares a formal resignation letter addressed to the Board of Directors / Managing Director of the company — specifying the effective date of resignation and the reasons (at least in general terms). TaxClue drafts the resignation letter ensuring it contains all legally required elements.

2

Company Acknowledges Resignation — Board Resolution

The company's Board convenes (can be a shorter notice meeting for casual vacancy) to take note of the auditor's resignation and record it by way of Board Resolution. TaxClue prepares the Board Resolution text. The Board also resolves to fill the casual vacancy under Section 139(8).

3

Prepare ADT-3 Statement of Reasons

TaxClue assists the resigning auditor in preparing the Statement of Reasons to be attached to ADT-3 — covering: (i) reasons for resignation, (ii) whether there are any concerns about the company's affairs that should be brought to the notice of the ROC or Central Government (mandatory disclosure under Section 140(2) proviso). The statement must be accurate, complete, and carefully worded to protect the auditor's professional standing.

4

Complete Form ADT-3 on MCA V3

Form ADT-3 is filed on the MCA V3 portal under the company's CIN. The form captures: CIN of the company, date of resignation, reasons for resignation, and whether any concerns are being reported to ROC. The Statement of Reasons is uploaded as an attachment.

5

Sign with Auditor's DSC and File on MCA V3

ADT-3 is signed with the <b>auditor's DSC</b> — not the company director's DSC. This is a critical distinction: the filing is the auditor's obligation and must be authenticated by the auditor. TaxClue co-ordinates DSC signing with the CA firm and submits the form on MCA V3, sharing the SRN immediately upon acceptance.

6

Coordinate ADT-1 for Replacement Auditor

After ADT-3 is filed, TaxClue simultaneously co-ordinates ADT-1 for the company — covering the appointment of the replacement auditor to fill the casual vacancy. Under Section 139(8), the Board can appoint a replacement to fill the vacancy, and ADT-1 must be filed within 15 days of the appointment.

Documents Required

Documents Needed for Registration

What TaxClue Needs to File ADT-3
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Signed Resignation Letter

From the auditor addressed to Board of Directors — with date.

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Company's CIN (Corporate Identity Number)

From Certificate of Incorporation or MCA portal.

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Membership Number and FRN

Of the resigning auditor / CA firm.

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Date of Original Appointment

From ADT-1 filing or company records.

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Statement of Reasons for Resignation

Prepared and signed by the auditor.

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DSC (Digital Signature Certificate)

Of the resigning auditor / partner of the firm.

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Board Resolution of the Company

Acknowledging the resignation.

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Copy of Last Audit Report

Signed by resigning auditor (for reference).

Structure Comparison

Consequences of Not Filing ADT-3 in Time

Section 140(3) of the Companies Act imposes a mandatory penalty on the auditor who fails to file ADT-3 within the 30-day window.

Mid-Term ResignationResignation Due to ConcernsLate / Missed Filing
Who FilesResigning auditor (CA firm / individual CA)Resigning auditorAuditor on MCA V3 with their DSC
Reasons in FormDisclosed — typically routine / capacityStatement of concerns — sent to ROC + NFRASame as applicable scenario
Deadline30 days from resignation date30 days from resignation dateFile ASAP — penalty already applies
Late Fee₹100/day additional government fee₹100/day additional government fee₹100/day — accumulating
Penalty₹50,000 min — up to 5x audit fees₹50,000 min — up to 5x audit feesSame — applies from day 31
Who PenalisedAuditor — not the companyAuditor — not the companyAuditor — not the company
ActionFile immediately to limit further exposureFile immediately — NFRA reference if fraud suspectedFile immediately to stop daily fee accumulation
Post-Registration

Critical Timelines

ADT-3: 30 days from resignation — Filed by the auditor on MCA V3
ADT-1: 15 days from Board appointment — Filed by company for new auditor
AGM Ratification — Board-appointed auditor ratified at next AGM
Minimum Penalty: ₹50,000 — on auditor personally for non-filing
Maximum Penalty: 5x annual audit fees received from the company
Late Govt. Fee: ₹100/day — payable on MCA in addition to Section 140(3) penalty
Auditor's DSC Required — company director DSC not sufficient
Statement of Reasons — mandatory disclosure, legally sensitive
Why TaxClue

Why Choose TaxClue?

📅

30-Day Filing Guaranteed

We file ADT-3 well within the window to avoid the ₹50,000+ penalty.

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Statement of Reasons Drafted

Our CA reviews facts and drafts a balanced, legally protective statement.

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ADT-3 + ADT-1 Bundled

We file ADT-3 for outgoing auditor and ADT-1 for incoming — seamless transition.

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DSC Co-ordination

Auditor's DSC signing managed — not director's DSC.

Same-Day Filing for Urgent Cases

If deadline is imminent, we file ADT-3 same-day on urgent basis.

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5,000+ Companies Served

4.9★ Google rating. Trusted by auditors and companies.

FAQ

Frequently Asked Questions

Yes. The company must: (i) acknowledge the resignation via Board Resolution, (ii) appoint a replacement auditor to fill the casual vacancy (Board appointment), and (iii) file ADT-1 within 15 days of the Board appointment. The replacement must be ratified by members at the next AGM.
The statement must cover: (i) reasons for resignation, and (ii) whether there are any concerns about the company's affairs that should be brought to the notice of the ROC or Central Government. If fraud is suspected, the auditor may need to refer the matter to NFRA under Section 140(2) proviso.
The 30-day period runs from the date of the resignation letter (i.e., the date the auditor tenders their resignation) — not from the date the company acknowledges or accepts it.
The additional government late fee (₹100/day) accumulates until filing. The Section 140(3) penalty (₹50,000 minimum) is a separate statutory penalty that is adjudicated by ROC and cannot be waived — it applies regardless of reason for delay.
Yes. An auditor can resign at any time during their appointed tenure. There is no restriction on mid-term resignation. However, ADT-3 must be filed within 30 days, and the Statement of Reasons must be disclosed.
No. ADT-3 is not required when: (i) the auditor's term expires naturally at the AGM (this is retirement, not resignation), (ii) the company removes the auditor through a special resolution under Section 140(1) — the company files a different process in that case, (iii) the auditor was never formally appointed (e.g., acting/interim arrangements). ADT-3 applies only to a mid-term voluntary resignation by the appointed statutory auditor.
Don't Let the 30-Day Window Close

File ADT-3 — Before the Penalty Hits

TaxClue handles ADT-3 for resigning auditors — resignation letter drafting, Statement of Reasons, MCA V3 filing with auditor's DSC, and coordinating ADT-1 for the replacement auditor. Same-day filing on urgent basis.

🚀 File ADT-3 Now 📞 +91 98914 64610 💬 WhatsApp

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