Compliance of Indian Accounting Standards in 2023 by companies and NBFCs including its holding, subsidiaries, joint ventures and associates.
The Ministry of Corporate Affairs (MCA) has issued a notification dated 16th February, 2015 announcing the Companies (Indian Accounting Standards) Rules, 2015 for phase-wise revised roadmap for adoption and applicability of all 39 Indian Accounting Standards (Ind AS) for companies other than Banking companies, Insurance Companies and NBFCs.
The MCA had issued yearly amendment rules in the year 2016, 2017, 2018 and 2019 to amend the Companies (Indian Accounting Standards) Rules, 2015. Note that SEBI requires issuer companies to disclose financial information for the previous 5 financial years immediately preceding the year of filing of the offer document, while following uniform accounting policies for each of the financial years. Thus, on or after April 1, 2020, disclosures in all the previous five financial years will have to be made as per the IND AS principles.
Rule 4 of the Companies (Indian Accounting Standards) Rules, 2015 has specified the classes of companies which shall comply with the Ind AS in preparation of their financial statements and auditors of such companies while preparing their audit report. Financial Statements shall have same meaning as defined in clause (40) of Section 2 of the Companies Act, 2013.
The application of Ind AS is mainly based on the listing status and net worth of a company. As per the roadmap for implementation of Ind AS, all listed companies (except companies listed on SME exchanges) and companies having a net worth of ₹250 crore or more shall be required to adopt Ind AS.
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In accordance with clause (ii) of sub- rule (1) of Rule 4 of the Companies (Indian Accounting Standards) Rules, 2015, the following companies shall comply with Ind AS w.e.f. April 2016:
(a) Companies listed/in process of listing on Stock Exchanges in India or Outside India having net worth of ₹500 crore or more;
(b) Unlisted Companies having net worth ≥ ₹500 crore;
(c) Holding (Parent), subsidiary, joint venture or associate companies of above.
Therefore, Ind AS will first apply to all companies (Listed or Unlisted) having net worth of ₹500 crore or more for the accounting periods beginning on or after 1st April, 2016. In other words, the companies meeting the above threshold for the first time as on 31st March, 2021 shall apply Ind AS for the financial year 2021-22 onwards.
Clause (iii) of sub- rule (1) of Rule 4 of the Companies (Indian Accounting Standards) Rules, 2015 states that the following companies shall comply with Ind AS for the accounting periods beginning on or after 1st April, 2017:
(a) Companies listed/in process of listing on Stock Exchanges in India or Outside India having net worth of less than ₹500 crore;
(b) Unlisted companies having net worth of ≥ ₹250 crore but < ₹500 crore;
(c) Holding, Subsidiary, Associate and J.V. of Above.
Thus, from April 2017 Ind AS shall apply to all listed companies irrespective of their net worth whereas the unlisted companies shall be required to comply with Ind AS only if their net worth is equal to or exceeding ₹250 crore. In other words, the companies meeting the above threshold for the first time as on 31st March, 2021 shall apply Ind AS for the financial year 2021-22 onwards.
Note that the comparative information i.e. comparative figures for the preceding accounting period is required in both phase for the period ending 31st March 2016/2017 or thereafter. You should also note that the Rule do not mention the net worth criteria for holding, subsidiary, joint venture or associate companies and therefore even smaller companies in this category will be covered for the purpose of applicability of Ind AS.
MCA has issued Companies (Indian Accounting Standards) (Amendment) Rules, 2016 to amend Companies (Indian Accounting Standards) Rules, 2015.
Roadmap for implementation of Ind AS by Non-Banking Financial Companies:
As per clause (iv) of sub-rule (1) of Rule 4 of the Companies (Indian Accounting Standards) (Amendment) Rules, 2016, Non-Banking Financial Companies (NBFCs) shall comply with the Indian Accounting Standards (Ind ASs) in preparation of their financial statements and audit respectively, in the following manner, namely: –
The following NBFCs shall comply with the Indian Accounting Standards (Ind AS) for accounting periods beginning on or after the 1st April, 2018, with comparatives for the periods ending on 31st March, 2018, or thereafter—
(A) NBFCs having net worth of rupees ₹500 Crore or more;
(B) holding, subsidiary, joint venture or associate companies of companies covered under item (A).
The following NBFCs shall comply with the Indian Accounting Standards (Ind AS) for accounting periods beginning on or after the 1st April, 2019, with comparatives for the periods ending on 31st March, 2019, or thereafter—
NBFC means a Non-Banking Financial Company as defined in clause (f) of section 45-I of the Reserve Bank of India Act, 1934 and includes:
The term Net Worth shall have the meaning assigned to it in clause (57) of Section 2 of the Companies Act, 2013. For the purposes of calculation of net worth of companies, the following principles shall apply, namely:-
(a) The net worth shall be calculated in accordance with
(b) for companies falling under any of thresholds specified in Phase I and II above for the first time after 31st March, 2021, the net worth shall be calculated on the basis of the first audited financial statements ending after that date in respect of which it meets the thresholds.
The following companies are not required to prepare their financial statements in accordance with Ind AS:
i) The Insurance Companies, Banking Companies and Non-Banking Finance Companies.
ii) Companies whose securities are listed or are in the process of being listed on SME exchange.
SME Exchange shall have the same meaning as assigned to it in Chapter XB of the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2009.
iii) Overseas subsidiaries, associates, joint ventures of an Indian company is not required to prepare its stand-alone financial statements as per the Ind AS. Thus, they may prepare their standalone financial statements in accordance with its jurisdictional requirements.
However, it is apparent from the above fact that these entities will still have to report their Ind AS adjusted numbers for their Indian parent company to prepare consolidated Ind AS accounts.
Once a company starts following the Indian Accounting Standards (Ind AS) on the basis of specified criteria, it shall be required to follow the Ind AS for all the subsequent financial statements even if any of the criteria specified in this rule does not subsequently apply to it. However, the companies which are not required to follow Ind AS shall comply with the Accounting Standards (AS) as specified to the Companies (Accounting Standards) Rules, 2006.