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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 Audited Financial Statements

## 1. What must be circulated?

The following documents must be sent to members:

  • Financial Statements (FS) including Consolidated FS (CFS), if applicable
  • Auditor's Report
  • Every other document required by law to be annexed/attached to the FS (e.g., Board's Report)

## 2. To whom and when?

Must be sent not less than 21 days before the date of the General Meeting to:

  • Every member of the company
  • Every trustee for debenture-holders
  • Every other person entitled to receive notice of the GM

## 3. Shorter Notice (less than 21 days)

FS can be sent less than 21 days before GM with consent of:

Type of CompanyConsent Required
Company having share capitalMajority in number AND members holding ≥ 95% of paid-up share capital (carrying voting rights)
Company not having share capitalMembers having ≥ 95% of total voting power

## 4. Listed Companies – Deemed Compliance

In case of a listed company, it is sufficient compliance if:

  • FS are made available for inspection at its registered office at least 21 days before the GM, AND
  • A statement containing salient features is sent 21 days before GM in Form AOC-3 (or Form AOC-3A where Ind AS applies)

## 5. Mode of Sending

Type of CompanyMode
Listed companyE-mode
Public company with net worth > ₹1 crore AND turnover > ₹10 croreE-mode
OthersPhysical OR E-mode

## 6. Listed Companies – Subsidiary FS on Website

A listed company must place on its website:

  • Separate audited standalone FS of each subsidiary
  • Where the subsidiary is outside India (foreign subsidiary):
  • If audited FS are required under foreign law → upload audited FS
  • If not required → upload unaudited FS + translated copy (if not in English)

## 7. Inspection by Members

Members can:

  • Inspect FS during business hours at the Registered Office
  • Ask for copies of FS

## 8. Penalty for Default

  • Company: ₹25,000
  • Officer in default: ₹5,000

Worked example

### Example 1

Example: XYZ Ltd. (unlisted public company) has 100 members. It wishes to send FS only 15 days before AGM. Can it?

Yes, if it obtains consent of majority in number AND members holding ≥ 95% of paid-up share capital with voting rights.

### Example 2

Example: ABC Ltd. (listed) has a foreign subsidiary in Germany. German law does NOT require audit. How should ABC Ltd. comply with website-disclosure of subsidiary FS?

It must upload the unaudited FS of the German subsidiary and, if not in English, also upload a translated copy.

⚠️ Common exam mistakes

  • Forgetting trustees for debenture-holders are also entitled to receive FS.
  • Confusing the 95% consent requirement with the 21-day inspection rule for listed companies (both are different concepts).
  • Assuming all companies must send FS in e-mode – only listed and certain public companies are mandated.
  • Forgetting that Form AOC-3A is used where Ind AS applies (not AOC-3).
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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