Audit Trail

Background

In 2021, the Ministry of Corporate Affairs (MCA) introduced a significant amendment under the Companies Act, 2013 to enhance transparency and accountability in financial reporting. The amendment made it mandatory for companies to use accounting software that records an audit trail—a detailed log of all transactions and changes made in the books of accounts. Effective from April 1, 2023 (after deferments), this rule ensures that every transaction is tracked chronologically, including edits, deletions, and authorisations, helping detect fraud and errors. It aligns with global best practices and supports better compliance, governance, and integrity in financial records.

Purpose of Audit Trail

In today’s digital landscape, maintaining an accurate audit trail is no longer optional, it’s essential. Whether it’s financial data, IT processes, HR records, or operational procedures, audit trails provide critical documentation that helps organisations review past events and verify the actions of individuals involved.

  1. Promoting User Accountability

Audit trail empowers organisations to track user activities across their systems. They reveal who accessed sensitive information, what changes were made, and when these actions occurred. This not only discourages misconduct but also helps in holding individuals accountable for their actions.

 

  1. Ensuring Regulatory Compliance

Many industries operate under strict regulatory frameworks that demand meticulous record-keeping. Audit trails help businesses demonstrate compliance with such regulations, significantly reducing the risk of fines, penalties, or legal issues stemming from non-compliance.

 

  1. Strengthening Security Measures

By monitoring system events and user activity, companies can swiftly detect security threats or data breaches. Audit logs enable rapid investigation and response, helping to contain potential damage and bolster overall cybersecurity.

 

  1. Facilitating Issue Resolution

When problems arises, whether it’s a system malfunction, human error, or data inconsistency audit trails offer valuable insights. They allow organisations to retrace steps, uncover the root cause of the issue, and implement corrective measures efficiently.

Applicability of Audit Trial  

  • Maintaining a complete audit trail is key for tracing irregularities and fixing process gaps. It ensures transparency and accountability in business operations.
  • However, audit trails are mandatory only for companies registered under the Companies Act, 2013, such as:
  • Public & Private Limited Companies
  • One Person Companies (OPCs)
  • Government-Owned Companies
  • Not-for-Profit Organizations
  • Nidhi Companies
  • Foreign Companies (Branch office, Liaison office, Project office)

Time Period for Maintaining an Audit Trail

  • As per Section 128(5) of the Companies Act, 2013, companies are required to retain their books of accounts for at least eight financial years immediately preceding the current financial year. If a company exists for less than eight years, it must preserve records for all the years since its incorporation.
  • Additionally, all related vouchers and supporting documents must be properly maintained. In addition to this, companies are also required to maintain the audit trail for a minimum of eight years.

Best Practices for Maintaining an Effective Audit Trail

Implementing a strong audit trail isn’t just about compliance, it’s about safeguarding your business. Here are some best practices to follow:

  1. Regular Data Backups

Ensure frequent and secure backups to protect against data loss from system failures or cyber incidents. This allows for quick recovery when needed.

  1. User Authentication & Access Controls

Adopt strong user authentication methods and role-based access controls to ensure only authorised personnel can make changes. Data encryption further protects sensitive information.

  1. Periodic Audits

Schedule regular audits to review records, spot irregularities, and verify accuracy. Independent internal or external auditors can provide objective oversight.

  1. Automated Logging

Leverage automated tools to consistently record user actions and system events. This reduces manual errors and ensures complete, real-time tracking of activities.

Audit Trail Checklist under Companies Act, 2013

To enhance accountability and detect irregularities, every company that maintains its books of accounts electronically is required to implement an audit trail mechanism. This requirement, notified under the Companies (Accounts) Rules, 2014 (amended in 2022), mandates that a company’s accounting software must record an edit log or audit trail of each transaction.

Transaction particulars: Date, amount, and nature of each transaction.

Changes to books of accounts: Date and nature of each alteration.

Authorisation details: Names of individuals authorising transactions and changes.

Approval and rejection specifics: Names of those approving or rejecting transactions and changes.

Access to records: Details of access to records, including the date, time, and names of individuals accessing the books of accounts.

Backup and restoration activities: Details of all related activities concerning the books of accounts

Penalty for Non-Compliance

  • For companies, under Section 128(5), failure to comply with audit trail requirements results in a fine ranging from INR 50,000 to INR 500,000. Continued violations may incur further penalties, especially if financial reporting inaccuracies arise due to tampering or lack of an audit trail.
  • For directors, CFOs, and other authorized personnel, such as the Managing Director, the Chief Financial Officer (CFO), and other persons charged with the responsibility of complying with the provisions – personal liability can result in fines between INR 50,000 and INR 500,000
  • For Auditors who fail to report a company’s non-compliance with audit trail requirements, or who certify inaccurate financial statements, may be penalized under Section 147(2) of the Companies Act, 2013, with fines ranging from ₹25,000 to ₹5,00,000 or up to four times their remuneration, whichever is less.

 

 

Disclaimer: The information contained in this Article is intended solely for personal non-commercial use of the user who accepts full responsibility of its use. The information in the article is general in nature and should not be considered to be legal, tax, accounting, consulting or any other professional advice. We make no representation or warranty of any kind, express or implied regarding the accuracy, adequacy, reliability or completeness of any information on our page/article. 

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