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Microlesson · 5-min read

Tenure, Rotation & Cooling Period of Auditors (Section 139(2))

# Rotation, Tenure & Cooling Period of Auditors

## 1. Companies to Which Rotation Applies [Sec 139(2) read with Rule 5]

Rotation provisions apply to:

  • All Listed companies
  • Unlisted public companies with paid-up share capital ≥ ₹10 crore
  • Private companies with paid-up share capital ≥ ₹50 crore
  • All other companies (whether public/private) having borrowings from banks/PFIs or public deposits ≥ ₹50 crore

Exception: Rotation does NOT apply to:

  • One Person Company (OPC)
  • Small Company

## 2. Maximum Tenure

Type of AuditorMaximum Consecutive Tenure
Individual auditorOne term of 5 consecutive years
Audit firmTwo terms of 5 consecutive years each (= 10 years)

## 3. Cooling-Off Period

After the maximum tenure is completed, the auditor / firm is NOT eligible for re-appointment in the same company for 5 years.

### Q1: Can such an auditor be appointed as Internal Auditor of the company during the cooling period?

Ans: Yes – the prohibition is only on appointment as statutory auditor.

### Q2: Can such an auditor be appointed as Statutory Auditor of Holding or Subsidiary during cooling period?

Ans: No – the prohibition extends to the holding/subsidiary/associate of the same company.

## 4. Other Persons INELIGIBLE During Cooling Period [Rule 6]

The following are also ineligible for appointment during the cooling period of 5 years:

1. An audit firm having common partner(s) as the audit firm whose tenure has just expired.

2. Audit firms under the same network of audit firms – "same network" includes:

  • Same brand name / trade name
  • Common control

3. If an outgoing partner of an audit firm takes interchange of audit firm AND certifies FS, retires from the firm and joins another firm – such other firm becomes ineligible for appointment for 5 years.

## 5. Audit Committee – Recommendation of Incoming Auditor

The Audit Committee recommends the name of an individual auditor or audit firm who may replace the existing auditor on expiry of his/its tenure.

Worked example

### Example 1

Example: M/s X & Co. (a firm) was the auditor of ABC Ltd. (listed) for 2 terms of 5 years each ending 31-Mar-2024. Can it be re-appointed in ABC Ltd. for FY 2024-25?

No. Maximum tenure of 10 years is over. It must observe a cooling period of 5 years before re-appointment.

### Example 2

Example: During the cooling period, can M/s X & Co. be appointed as the statutory auditor of ABC Ltd.'s wholly-owned subsidiary?

No. The cooling period applies to appointment in holding / subsidiary / associate as well.

### Example 3

Example: Mr. P, partner of M/s X & Co., certified the FS of ABC Ltd. M/s X & Co.'s tenure expired. Mr. P now joins M/s Y & Co. Can M/s Y & Co. be appointed as the new auditor of ABC Ltd.?

No – M/s Y & Co. becomes ineligible for 5 years.

⚠️ Common exam mistakes

  • Confusing the tenure: Individual = 5 years (1 term); Firm = 10 years (2 terms).
  • Forgetting that rotation does NOT apply to OPC and Small Companies.
  • Believing the outgoing auditor cannot be appointed as internal auditor during cooling – they CAN.
  • Forgetting the 'common network' and 'common partner' restriction.
  • Forgetting that the cooling restriction extends to holding/subsidiary/associate companies.
Bare-Act text Section 139(2) read with Rule 5 & 6 of Companies (Audit and Auditors) Rules, 2014 · 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 under clause (a) 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 under clause (b), shall not be eligible for re-appointment as auditor in the same company for five years from the completion of such term.
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