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Microlesson · 5-min read

Right of Members to Copies of Audited Financial Statements (Section 136)

# Section 136 – Right of Members to Copies of Audited Financial Statements

## 1. What Must Be Sent?

A copy of the following must be sent to every person entitled:

1. Financial Statements (including consolidated FS, if any).

2. Auditor's Report.

3. Every other document required by law to be annexed or attached to the financial statements.

## 2. Who Is Entitled to Receive?

  • Every member of the company.
  • Every trustee for debenture-holders.
  • All other persons entitled (e.g., auditors).

## 3. Time of Dispatch

Documents must be sent at least 21 days before the date of the General Meeting.

### Shorter Notice Permitted

Documents may be sent at less than 21 days before the meeting if consented to by:

Company With Share CapitalCompany Without Share Capital
Majority in number entitled to vote AND who represent ≥ 95% of paid-up share capitalMembers having ≥ 95% of total voting power

## 4. Compliance for Listed Companies

In the case of listed companies, it is sufficient compliance if:

  • The financial statements (including auditor's report and other documents) are made available for inspection at the registered office during working hours for at least 21 days before the meeting, AND
  • A statement containing the salient features of the documents in the prescribed form (Form AOC-3 / AOC-3A where applicable to Ind-AS) is sent to every member and trustee/entitled person 21 days before the meeting.

## 5. Mode of Sending

Type of CompanyMode
Listed CompanyElectronic mode (e-mail)
Public Company having Net Worth > ₹1 crore AND Turnover > ₹10 croreElectronic mode
Other CompaniesPhysical or electronic (as per member's request)

## 6. Web Posting

A company having a website must place its financial statements (including consolidated FS, auditor's report and all annexed documents) on its website.

## 7. Listed Holding Company Disclosure

A listed holding company shall also place separate audited accounts of each subsidiary on its website and shall provide a copy to any shareholder who asks for it.

## 8. Penalty

PersonPenalty
Company₹25,000
Every Officer in Default₹5,000

Worked example

### Example 1

Q. A listed company's AGM is scheduled for 30 September. It is sending only the salient features in Form AOC-3 to members instead of full accounts. Is this valid?

A. Yes. For listed companies, sending the statement of salient features (AOC-3) 21 days before AGM (i.e., by 9 September) is sufficient compliance, provided the full FS are made available for inspection at the registered office during working hours for 21 days before the meeting.

### Example 2

Q. Can FS be sent only 10 days before the AGM?

A. Yes, if members of share-capital company give consent: majority in number AND representing ≥ 95% of paid-up share capital. For non-share-capital company, members having ≥ 95% voting power must consent.

⚠️ Common exam mistakes

  • Using '21 days from' instead of '21 days before' the meeting date.
  • For shorter notice, omitting the requirement of '95% paid-up capital' along with majority in number.
  • Confusing AOC-3 (salient features for listed companies) with AOC-1 (subsidiary accounts).
  • Forgetting that listed holding companies must also display separate subsidiary accounts on the website.
Bare-Act text Section 136 · Companies Act, 2013 · click to expand
Section 136(1): Without prejudice to the provisions of section 101, a copy of the financial statements, including consolidated financial statements, if any, auditor's report and every other document required by law to be annexed or attached to the financial statements, which are to be laid before a company in its general meeting, shall be sent to every member of the company, to every trustee for the debenture-holder of any debentures issued by the company, and to all persons other than such member or trustee, being the person so entitled, not less than twenty-one days before the date of the meeting.
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