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Microlesson · 5-min read

CARO 2020: Applicability and Exemptions

## CARO 2020: Companies (Auditor's Report) Order, 2020

### What is CARO?

CAR0 2020 requires auditors to report on additional specific matters beyond the standard audit report under the Companies Act. It is issued by the Central Government under Sec 143(11).

### General Rule: Who Does CARO Apply To?

CARO 2020 applies to ALL companies including Foreign Companies

EXCEPT the following (completely excluded):

Excluded Category
Banking Companies
Insurance Companies
Section 8 Companies (Non-profit)
OPC (One Person Company)
Small Companies
Certain Private Companies (only if ALL 4 conditions met)

### 4 Conditions for Private Company Exemption

A private company is exempt from CARO only if it satisfies ALL FOUR conditions simultaneously:

#ConditionLimit
1NOT a subsidiary or holding company of a Public Company
2Paid-up Share Capital + Reserves & Surplus (all reserves including revaluation)≤ ₹1 crore (as on BS date)
3Total Borrowings from Bank or Financial Institution≤ ₹1 crore (at any time during year)
4Total Revenue (including revenue from discontinued operations)≤ ₹10 crores

> Key Rule: If even ONE condition is not met → CARO applies to that private company.

### Definition of Small Company (for reference)

A company is a Small Company if it is:

  • Not a public company, AND
  • Paid-up share capital ≤ ₹4 crores, AND
  • Turnover ≤ ₹40 crores (as per preceding FY)

### Quick Decision Chart

```

Is company a Bank / Insurance / Sec8 / OPC / Small Co.?

→ YES: CARO not applicable

→ NO:

Is it a Private Company?

→ YES: Check all 4 conditions

All 4 satisfied? → CARO NOT applicable

Any 1 fails? → CARO IS applicable

→ NO (Public Co. / Foreign Co.): CARO IS applicable

```

Worked example

### Example 1

Alpha Private Ltd: (1) Not subsidiary of public co ✅, (2) Paid-up SC + R&S = ₹80 lakhs ✅, (3) Bank borrowings = ₹50 lakhs ✅, (4) Revenue = ₹8 crores ✅. All 4 conditions satisfied → CARO NOT applicable.

### Example 2

Beta Private Ltd: (1) Not subsidiary ✅, (2) Paid-up SC + R&S = ₹80 lakhs ✅, (3) Bank borrowings = ₹1.5 crores ❌ (exceeds ₹1 crore limit), (4) Revenue = ₹8 crores ✅. Condition 3 fails → CARO IS applicable.

### Example 3

Gamma Private Ltd is a 100% subsidiary of Delta Public Ltd. Since it is a subsidiary of a public company, condition 1 fails immediately → CARO IS applicable regardless of size or financials.

### Example 4

Delta Ltd is a Foreign Company operating in India. CARO 2020 applies to foreign companies (they are not in the exceptions list) → CARO IS applicable.

⚠️ Common exam mistakes

  • Thinking ALL private companies are exempt from CARO — only private companies satisfying ALL 4 conditions are exempt
  • Using OR logic for the 4 conditions — ALL 4 must be satisfied simultaneously for exemption
  • Forgetting that revaluation reserve is included in Reserves & Surplus for condition 2
  • Thinking CARO does not apply to foreign companies — foreign companies are included (only specific categories are excluded)
  • Checking borrowings only at year-end — condition 3 requires borrowings check at ANY TIME during the year
  • Confusing CARO private company thresholds (₹1Cr SC+RS, ₹1Cr borrowings, ₹10Cr revenue) with Small Company definition thresholds (₹4Cr SC, ₹40Cr turnover)
Reference: Paragraph 2 — Applicability — Companies (Auditor's Report) Order, 2020
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