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Microlesson · 5-min read

CARO 2020 – Applicability and Exemptions

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

### What is CARO?

CARO is an order issued by the Central Government under Section 143(11) of the Companies Act, 2013. It requires auditors to report on specific matters beyond the standard audit report, providing additional accountability for company operations.

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### General Rule: CARO Applies to Every Company Including Foreign Companies

Exceptions (entities exempt from CARO 2020):

Exempt EntityGoverning Provision
Banking companySection 5(c), Banking Regulation Act, 1949
Insurance companyInsurance Act, 1938
Section 8 company (not-for-profit)Section 8, Companies Act, 2013
One Person Company (OPC)Section 2(62), Companies Act
Small companySection 2(85), Companies Act
Qualifying private limited companies(See four-condition test below)

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### Special Exemption: Private Limited Companies

A private limited company is exempt only if ALL four conditions are satisfied simultaneously:

ConditionThreshold
Not a subsidiary or holding company of a public company
Paid-up capital + Reserves & Surplus≤ ₹1 crore as on Balance Sheet date
Total borrowings from any bank or FI≤ ₹1 crore at any point during the FY
Total revenue (Sch. III, including discontinuing operations)≤ ₹10 crore during the FY

> Critical exam point: Failing even ONE condition means CARO applies in full.

> The borrowing test is at any point in time during the year — not just at year-end. A temporary overdraft exceeding ₹1 crore triggers CARO.

Worked example

### Example 1

XYZ Pvt Ltd (not a subsidiary of any company) has: paid-up capital ₹80 lakh, general reserves ₹30 lakh, bank borrowings peaking at ₹95 lakh during the year (₹70 lakh at year-end), and total revenue ₹8 crore. Is CARO 2020 applicable?

Answer: Check all four conditions: (1) Not a subsidiary of a public company ✓; (2) Paid-up capital + Reserves = ₹1.10 crore — exceeds ₹1 crore ✗. Since condition 2 is violated, CARO 2020 is applicable to XYZ Pvt Ltd.

### Example 2

ABC Pvt Ltd is a wholly-owned subsidiary of PQR Ltd (a listed public company). ABC's paid-up capital is ₹40 lakh, reserves ₹20 lakh, bank borrowings ₹50 lakh, and revenue ₹6 crore. Does CARO apply?

Answer: Yes. ABC Pvt Ltd is a subsidiary of a public company. The first condition of the private company exemption (not being a subsidiary/holding of a public company) is not satisfied. CARO 2020 applies regardless of the financial thresholds being within limits.

⚠️ Common exam mistakes

  • Thinking CARO applies only to public companies — it applies to all companies including foreign companies, with limited exemptions.
  • Treating the private company exemption conditions as 'any one of four' instead of 'all four simultaneously'.
  • Using year-end borrowings instead of peak borrowings — the test is whether borrowings exceeded ₹1 crore at any point during the FY.
  • Forgetting that a private company that is a subsidiary of a public company cannot claim the private company exemption even if all financial thresholds are met.
  • Treating Section 8 (not-for-profit) companies as always being small or OPC — they are separately exempt as a distinct category.
Reference: Paragraph 2 – Applicability — Companies (Auditor's Report) Order, 2020 – Ministry of Corporate Affairs
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