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Microlesson · 5-min read

CARO 2020 – Core Investment Companies (Clause xvi(b))

## CARO 2020 Clause (xvi)(b) – Core Investment Companies (CIC)

### What the Auditor Must Report

The auditor must examine two things:

1. Is the company a CIC? If yes, does it continue to fulfil the RBI criteria for a CIC?

  • Includes exempted or unregistered CICs — they must still satisfy the applicable criteria continuously.

2. Multiple CICs in the Group? If the group of which the company is a part has more than one CIC, the auditor must indicate the number of CICs forming part of the group.

### Key Definitions

TermMeaning
CICCore Investment Company — an NBFC holding ≥ 90% assets as investments in equity/preference shares, bonds, debentures, debt or loans in group companies, and not carrying on any other financial activity
Exempted CICA CIC with asset size < ₹100 crore or one that raises no public funds and has no public interest
Registered CICAsset size ≥ ₹100 crore AND raises public funds — must register with RBI under Section 45-IA of the RBI Act, 1934

### Reporting Decision Tree

```

Is the company a CIC?

├── No → Report not applicable

└── Yes

├── Does it continue to fulfil CIC criteria? → Report Yes/No

└── Does the GROUP have more than one CIC?

├── No → State so

└── Yes → Indicate the NUMBER of CICs in the group

```

Worked example

### Example 1

Example 1 – Single CIC in Group:

ABC Ltd. qualifies as a CIC with assets > ₹100 crore and has obtained RBI registration. No other entity in the group is a CIC.

CARO Reporting: Auditor states that the company is a registered CIC, continues to fulfil CIC criteria, and there is only one CIC in the group.

### Example 2

Example 2 – Multiple CICs in Group:

XYZ Group has a parent holding company (CIC-1) and a sub-holding company (CIC-2), both qualifying as CICs.

CARO Reporting: Auditor states that the group has 2 CICs as part of the group and identifies both entities.

⚠️ Common exam mistakes

  • Confusing a CIC with a regular NBFC — a CIC has a specific asset composition requirement (≥90% in group company instruments).
  • Forgetting to check whether an exempted CIC still meets its criteria — the obligation to verify continues even without RBI registration.
  • Reporting only the company's own CIC status without checking whether the GROUP has multiple CICs.
  • Mixing up Section 45-IA of the RBI Act (registration requirement) with Section 45-IC (reserve fund requirement).
Bare-Act text Para 3(xvi)(b) · Companies (Auditor's Report) Order, 2020 (CARO 2020) · click to expand
Whether the company is a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India; if so, whether it continues to fulfil the criteria of a CIC, and in case the company is an exempted or unregistered CIC, whether it continues to fulfil such criteria; and if the group of which the company is a part has more than one CIC as part of the group, indicate the number of CICs which are part of the group.
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