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Microlesson · 5-min read

Term, Cooling Period, Rotation and Remuneration of Auditors – Sections 139 and 142

# Term, Cooling Period, Rotation & Remuneration [Sections 139 & 142]

## (1) Term of Auditor — To Whom Does Rotation Apply?

### Companies subject to mandatory rotation (term limit):

  • Listed company,
  • Unlisted public company with paid-up share capital ≥ ₹ 10 crores,
  • Private company with paid-up share capital ≥ ₹ 50 crores, OR
  • Any company having public borrowings from financial institutions/banks OR public deposits ≥ ₹ 50 crores.

> Exemptions: OPC and Small Company are exempt.

### Maximum Term (for above companies):

TypeMaximum Term
Individual1 term of 5 consecutive years
Audit Firm2 terms of 5 consecutive years (i.e., 10 years)

### Other Companies

Can appoint or re-appoint an auditor for any number of terms (no rotation requirement).

## (2) Important Notes on Term

  • No requirement to ratify auditor's appointment at every AGM (the earlier requirement is removed).
  • Period as 1st auditor and period filling a casual vacancy are NOT counted for the subsequent auditor's term.
  • Change in constitution of auditor (e.g., proprietorship to firm, or vice versa) is treated as appointment of new auditor. Company must file Form ADT-1 after the next AGM.

## (3) Cooling Period

After completing the maximum term:

  • Individual or audit firm shall not be eligible for re-appointment in the same company as statutory auditor for 5 years from completion of the term.

### Scope of Cooling Period

Permitted During Cooling PeriodNOT Permitted
Audit of other companies (e.g., subsidiary, associate)Statutory audit of the same company
Other services (non-statutory audit) to the same company

### Common Partner Rule

On the date of appointment of an audit firm, it must NOT have any common partner who is or was a partner in another firm whose tenure expired in the immediately preceding FY. If there are common partners, the new firm also serves the 5-year cooling period.

### Retiring Partner Joining Another Firm

If a partner who certified the FS retires from a firm (whose term has completed) and joins another firm, that other firm also becomes ineligible for appointment in the same company for 5 years.

### Network Firm Rule

A person/firm associated with the outgoing auditor under the same network (operating under same brand name, trade name, or common control) is also ineligible.

## (4) Rotation Within the Term (Optional)

Members may decide that:

  • Audit shall be conducted by more than one auditor, OR
  • In case of a firm, the audit partner and his team shall be rotated at intervals decided by members.

### Joint Auditors

Where joint auditors are appointed, rotation may be arranged so that all joint auditors do not complete their terms in the same year (to ensure continuity).

## (5) Remuneration of Auditors [Section 142]

### Components of Remuneration

Remuneration includes:

  • Fee payable to auditor,
  • Out-of-pocket expenses incurred for audit, and
  • Any facility extended to him.

Remuneration EXCLUDES:

  • Amount paid for any other services rendered at the request of the company (e.g., tax services).

### Who Fixes Remuneration?

Auditor TypeAuthority
First auditor appointed by BODBOD fixes remuneration
Other auditorsFixed in general meeting, or in the manner determined in general meeting

Worked example

### Example 1

Example: First Auditor Tenure Not Counted

M Ltd. (listed company) appointed Mr. X as its first auditor. He held office till the conclusion of the 1st AGM. At the 1st AGM, Mr. X was re-appointed as auditor till the conclusion of the 6th AGM.

Analysis:

  • The period of appointment as 1st auditor is not counted towards the 5-year term as subsequent auditor.
  • Mr. X is being appointed as subsequent auditor for his first term of 5 consecutive years (1st to 6th AGM).
  • This is a valid appointment under Section 139.

Conclusion: Valid. Mr. X can also be re-appointed for one more 5-year term after this (as he is an individual, only 1 term — hence, after 6th AGM, he must rotate out and serve 5-year cooling period).

⚠️ Common exam mistakes

  • Forgetting that OPC and small companies are exempt from the mandatory rotation rules under Section 139(2).
  • Counting the period as first auditor or in casual vacancy towards the 5-year term as subsequent auditor — they are NOT counted.
  • Forgetting the common partner rule — a new firm with a common partner from the outgoing firm also serves the cooling period.
  • Believing the cooling period applies to all services — it applies only to statutory audit of the same company.
  • Mixing up individual vs firm term limits: Individual = 1 term of 5 yrs; Firm = 2 terms of 5 yrs (10 yrs).
  • Including remuneration for 'other services' in audit remuneration — they are excluded.
  • Forgetting that re-appointment ratification at every AGM was removed by amendment — it is no longer required.
  • Confusing rotation requirement triggers: paid-up ≥ ₹ 10 cr (unlisted public), ≥ ₹ 50 cr (private), or borrowings/deposits ≥ ₹ 50 cr (any company).
Bare-Act text Sections 139(2), 139(3), 139(4) and 142 · Companies Act, 2013 · click to expand
Section 139(2) — No listed company or a company belonging to such class or classes of companies as may be prescribed, shall appoint or re-appoint — (a) an individual as auditor for more than one term of five consecutive years; and (b) an audit firm as auditor for more than two terms of five consecutive years: Provided that — (i) an individual auditor who has completed his term...shall not be eligible for re-appointment as auditor in the same company for five years from the completion of his term; (ii) an audit firm which has completed its term...shall not be eligible for re-appointment...Section 142 — The remuneration of the auditor of a company shall be fixed in its general meeting or in such manner as may be determined therein...
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