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Microlesson · 5-min read

Books of Accounts in Electronic Mode [Rule 3]

## Rule 3 of Companies (Accounts) Rules, 2014 — Books in Electronic Mode

When a company chooses to maintain its BoA in electronic form, it must comply with these conditions:

### A — Accessibility

BoA shall remain accessible in India at all times so as to be usable for subsequent reference.

### F — Features of Accounting Software

The accounting software used must:

  • Record an audit trail of every transaction;
  • Create an edit log of each change made in BoA along with the date of such change; and
  • Ensure that the audit trail cannot be disabled.

### O — Original Format Retention

Books shall be retained completely in the format in which they were originally generated, sent or received, or in a format which presents the information accurately. The information must remain complete and unaltered, including branch information.

### L — Legible Display

The electronic record shall be capable of being displayed in a legible form.

### S — Storage System

A proper system for storage, retrieval, display or printout of the e-records must exist.

### E — No Unauthorised Disposal

E-records shall not be disposed of or rendered unusable unless permitted by law.

### B — Back-up

Back-up of books maintained in electronic mode shall be kept in servers physically located in India on a periodic (daily) basis.

> Mnemonic: "A-F-O-L-S-E-B"Accessible, Features, Original, Legible, Storage, E-disposal, Back-up.

### Annual Intimation to ROC

The company shall intimate the ROC on an annual basis at the time of filing financial statements:

1. The name of the service provider

2. The IP address of the service provider

3. The location of the service provider (wherever applicable)

4. Where the books are maintained on a cloud, such address as provided by the service provider

5. If the service provider is located outside India, the name and address of the person in control of the books of account and other books and papers in India

Worked example

### Example 1

Q. XYZ Ltd. maintains BoA on cloud servers located in Singapore. Daily back-up is kept on a server in Bangalore. Is this compliant?

A. Partly. Daily backup on Indian server is compliant. But because the service provider is outside India, XYZ Ltd. must annually intimate the ROC the name and address of the person in control of those books in India, in addition to the standard particulars.

⚠️ Common exam mistakes

  • Forgetting that back-up servers must be located in India, even if the primary server is abroad.
  • Stating that intimation to ROC is one-time — it is required on an annual basis while filing FS.
  • Missing the audit trail requirement — the software must not allow the audit trail to be disabled.
Bare-Act text Rule 3 · Companies (Accounts) Rules, 2014 · click to expand
Rule 3, Companies (Accounts) Rules, 2014 — Manner of Books of Account to be kept in Electronic Mode.
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