Schedule III Compliance Checker — Division Finder & 16-Disclosure Score
This free tool answers two questions for any company: which Division of Schedule III to the Companies Act 2013 applies to your financial statements, and how compliant are you with the FY 2021-22 disclosure amendments? Step 1 identifies Division I, II or III from your accounting framework. Step 2 lets you tick off the 16 mandatory additional disclosures introduced by MCA Notification G.S.R. 207(E) and gives a readiness score. Built and reviewed by Chartered Accountants at Patron Accounting LLP, it runs entirely in your browser so your company data never leaves your device.
Schedule III Division & Disclosure Check
Tick each disclosure your financial statements already include (or that is genuinely not applicable to your company). Then score readiness.
How to Use the Schedule III Compliance Checker
This tool is built for directors, finance teams and auditors of Indian companies finalising financial statements. It removes two common errors: applying the wrong Schedule III Division, and missing one of the 16 additional disclosures the MCA made mandatory from FY 2021-22.
- Select your accounting framework. Indian GAAP maps to Division I, Ind AS to Division II, and an Ind AS NBFC to Division III.
- Select the financial year. The 2021 amendment disclosures apply for years commencing on or after 1 April 2021.
- Find the applicable Division. You get a clear verdict identifying the correct Division and what it governs.
- Score disclosure readiness. Tick each of the 16 mandatory disclosures your financial statements include, then generate a compliance percentage and band.
CA Tip: Tick a disclosure only if it is genuinely addressed — either with the required tabular note or with a clear "not applicable" statement supported by facts. Auditors test the basis of negative disclosure, not just its presence.
The Three Divisions of Schedule III
Schedule III to the Companies Act 2013 prescribes the format of the balance sheet, statement of profit and loss and notes, so that financial statements are uniform and comparable. It is split into three Divisions based on the accounting framework the company follows.
| Division | Applies To | Framework |
|---|---|---|
| Division I | Companies on Accounting Standards | Companies (Accounting Standards) Rules — Indian GAAP |
| Division II | Companies on Ind AS | Companies (Indian Accounting Standards) Rules |
| Division III | NBFCs on Ind AS | Ind AS, with NBFC-specific presentation |
Schedule III also provides that if compliance with the Act or applicable Accounting Standards requires any change in treatment or disclosure — including addition, amendment, substitution or deletion in any head or sub-head — that change must be made and the requirements of the Schedule stand modified accordingly. Detailed guidance is published by the ICAI in its Guidance Notes on Schedule III, and the Schedule itself is part of the Companies Act 2013 administered by the Ministry of Corporate Affairs and available via India Code.
The 16 Mandatory FY 2021-22 Disclosures
MCA Notification G.S.R. 207(E) dated 24 March 2021, issued by the Ministry of Corporate Affairs, substantially expanded Schedule III for financial years commencing on or after 1 April 2021. The amendments apply across Divisions I, II and III. The readiness checklist in this tool covers the 16 disclosure areas below.
| # | Disclosure Requirement |
|---|---|
| 1 | Shareholding of promoters and % change during the year |
| 2 | Mandatory rounding off based on Total Income |
| 3 | Current maturities of long-term borrowings under short-term borrowings |
| 4 | Trade receivables ageing schedule |
| 5 | Trade payables ageing schedule (MSME / others / disputed) |
| 6 | CWIP ageing schedule |
| 7 | Intangible assets under development ageing schedule |
| 8 | Title deeds of immovable property not in company's name |
| 9 | Loans / advances to promoters, directors, KMP, related parties |
| 10 | Details of benami property held and proceedings |
| 11 | Reconciliation of returns/statements filed with banks (working capital) |
| 12 | Wilful defaulter status disclosure |
| 13 | Relationship / transactions with struck-off companies |
| 14 | Undisclosed income surrendered in tax assessments |
| 15 | CSR expenditure disclosure (Section 135) |
| 16 | Crypto-currency / virtual currency holdings and results |
Note: Other 2021 amendments also apply, including financial ratios with explanations for variances over 25%, utilisation of borrowed funds and share premium, and registration/satisfaction of charges with the Registrar. Treat the list above as the core checklist, not an exhaustive substitute for the full Schedule III text.
Mandatory Rounding Off — A Frequently Missed Change
Until FY 2020-21, rounding off figures in the financial statements was optional and, where done, was based on turnover. From FY 2021-22 it is mandatory, and the criterion is Total Income, not turnover. A company can no longer present absolute, unrounded figures.
Total Income ≥ ₹100 crore: round to lakhs, millions or crores
Basis = Total Income (not Turnover) — and it is now compulsory
The rounding multiple must be applied consistently throughout the financial statements. This is one of the most commonly overlooked amendments because it is a presentation rule rather than a new note, yet inconsistent or absent rounding is a Schedule III non-compliance the auditor will flag.
Why Schedule III and CARO 2020 Move Together
Many of the 2021 Schedule III disclosures intentionally mirror CARO 2020 reporting clauses. The MCA aligned the two frameworks so that the company's own financial statements and the statutory auditor's report present consistent information, reducing the room for mismatched or contradictory disclosure.
| Topic | Schedule III Disclosure | CARO 2020 Clause |
|---|---|---|
| Title deeds | Property not in company's name | Clause (i)(c) |
| Benami property | Proceedings and amounts | Clause (i)(e) |
| Wilful default | Defaulter status | Clause (ix)(b) |
| Undisclosed income | Surrendered in tax | Clause (viii) |
| Working capital | Bank reconciliation | Clause (ii)(b) |
Because the frameworks are linked, a gap in a Schedule III disclosure usually surfaces again as a CARO qualification, and audit quality across both is overseen by the NFRA. Preparing both together is far more efficient. For end-to-end support, see our statutory audit and internal audit services, and the related CARO 2020 Self-Assessment tool.
CA Tip: Build the Schedule III disclosure file and the CARO working papers from the same underlying evidence — title deed registers, MSME vendor master, bank statements. Single-sourcing the evidence eliminates the most common cause of financial-statement-vs-audit-report mismatches.
Note: This tool gives an indicative Division verdict and disclosure score for planning only. The binding determination of the applicable Division and the completeness of Schedule III disclosures rests with the preparer and the statutory auditor, based on the company's actual framework and the rules for the specific financial year. Confirm with a Chartered Accountant.
Need Schedule III Compliant Financial Statements?
Patron Accounting LLP prepares and audits Schedule III compliant financials — for Pune, Mumbai, Delhi, Gurugram and pan-India clients.