XBRL Applicability Under the Companies Act: Who Must File AOC-4 XBRL?
A company must file its financial statements in e-form AOC-4 XBRL if it meets any one of four tests in Rule 3(1) of the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015: it is listed in India (or is an Indian subsidiary of a company listed in India), it has paid-up capital of ₹5 crore or more, it has turnover of ₹100 crore or more, or it must prepare Ind AS financial statements. NBFCs, housing finance companies, banking companies and insurance companies are exempt, and a company that has filed in XBRL once must keep filing in XBRL under Rule 3(2).
Last reviewed: 26 September 2026, against the Rules as amended up to the 6 June 2025 notification (in force 14 July 2025). Check the current text on the MCA site before you sign off a filing.
Which companies must file financial statements in XBRL?
Rule 3(1) requires the following classes to file financial statements and other documents under Section 137 of the Companies Act, 2013, with the Registrar in e-form AOC-4 XBRL:
| Limb | Test | Note |
|---|---|---|
| (i) | Companies listed with stock exchanges in India, and their Indian subsidiaries | The subsidiary's own size is irrelevant |
| (ii) | Paid-up capital of ₹5 crore or above | |
| (iii) | Turnover of ₹100 crore or above | |
| (iv) | Companies required to prepare financial statements under the Companies (Indian Accounting Standards) Rules, 2015 | Size and listing are irrelevant |
The tests are alternatives. One is enough. The taxonomy follows the accounting framework: Annexure-II (commercial and industrial, AS) for companies on the Companies (Accounting Standards) Rules, and Annexure-II A for Ind AS companies.
Which companies are exempt from XBRL filing?
The proviso to Rule 3(1) exempts non-banking financial companies, housing finance companies, and companies engaged in the business of banking and insurance. These file the ordinary AOC-4, even if they meet a size test or prepare Ind AS statements. The earlier version of the rule also exempted the power sector; that exemption was removed when the rule was amended in November 2017, so a power company meeting any limb must now file in XBRL. Old checklists that still say "power sector exempt" are a common source of wrong-form filings.
What is the once-filed-always-file rule in Rule 3(2)?
Rule 3(2) says a company that has filed its financial statements in XBRL under Rule 3(1) must continue to file in XBRL in every later year, even if it no longer falls within any of the classes above. Rule 3(3) similarly keeps companies that filed under the 2011 XBRL Rules on the XBRL track.
In practice: a company that crossed ₹100 crore turnover once and filed AOC-4 XBRL stays in XBRL after turnover falls back. Filing plain AOC-4 in the next year because "we are below the limits now" is a defective filing.
How do the thresholds work in a real case?
Take three unlisted private companies for FY 2025-26, none of them an NBFC, bank or insurer:
| Company | Paid-up capital | Turnover | Ind AS? | Filed XBRL before? | Result |
|---|---|---|---|---|---|
| A | ₹4.2 crore | ₹96 crore | No | No | Plain AOC-4 (below both limits) |
| B | ₹4.2 crore | ₹103 crore | No | No | AOC-4 XBRL under limb (iii); Annexure-II taxonomy |
| C | ₹0.5 crore | ₹9 crore | Yes (group cascade) | No | AOC-4 XBRL under limb (iv); Annexure-II A taxonomy |
If Company B's turnover drops to ₹80 crore in FY 2026-27, it still files AOC-4 XBRL because of Rule 3(2). If Company A grows to ₹102 crore next year, it enters XBRL that year and stays in.
You can test any profile in the XBRL applicability checker, which returns the limb that applies, the taxonomy, and a working paper you can file.
What is the difference between AOC-4 and AOC-4 XBRL?
Both forms file financial statements under Section 137, due within 30 days of the annual general meeting. The difference is the format of the data. AOC-4 XBRL carries the financial statements as a tagged XBRL instance document validated against the MCA taxonomy. Since Rule 3(1A) was inserted by the 2025 amendment (in force 14 July 2025), a company filing under Rule 3(1) must also attach a signed copy of the financial statements, authenticated as specified in Section 134 (including the Board's report, auditors' report and other documents), in PDF format in the same form.
What mistakes do CAs and auditors make on XBRL applicability?
- Testing size only. Missing limb (iv): a small Ind AS subsidiary is in scope regardless of capital or turnover. See the Ind AS applicability phase test for that first step.
- Missing the Indian-subsidiary limb. A ₹3 crore-turnover subsidiary of an Indian-listed parent must file XBRL. A subsidiary of a company listed only abroad is not caught by limb (i).
- Forgetting Rule 3(2). Applicability is not re-tested from scratch each year.
- Applying the exemption too broadly. The proviso names specific sectors. A non-financial company with a finance-sounding name is not exempt.
- Using the wrong taxonomy. AS companies and Ind AS companies tag against different annexures.
- Leaving out the PDF. Since July 2025 the signed statements, Board's report and auditors' report must go in as a PDF with the XBRL form.
- No record of the test. Keep a dated working paper of each limb, the figures used and the conclusion.
What about stock exchange filings by listed companies?
This post covers the Registrar filing under Section 137. Listed companies also submit results and reports to the stock exchanges under SEBI's own requirements, which are separate. They are not covered here, so check the current SEBI and exchange circulars for that side.
How does this fit into the audit file?
Applicability is a small conclusion that carries a large penalty risk if wrong, so it should be recorded like any other compliance test. Whatever you use to assemble engagement reporting (for example CORAA's Report Studio), keep the applicability conclusion alongside it, with the source figures for capital and turnover traced to the audited balance sheet and statement of profit and loss.
Frequently asked questions
Which companies must file AOC-4 XBRL?
Listed companies and their Indian subsidiaries, companies with paid-up capital of ₹5 crore or more, companies with turnover of ₹100 crore or more, and companies required to prepare Ind AS financial statements. Any one test is enough, subject to the exemptions for NBFCs, housing finance, banking and insurance companies.
Is an NBFC with Ind AS financial statements required to file in XBRL with MCA?
No. The proviso to Rule 3(1) exempts NBFCs, so an Ind AS NBFC files the ordinary AOC-4 with MCA. Regulatory returns to the RBI follow that regulator's own requirements.
If my turnover falls below ₹100 crore, can I go back to plain AOC-4?
No. Under Rule 3(2), once a company has filed in XBRL it must continue to do so in every succeeding year, even if it no longer meets any test.
Does the ₹5 crore and ₹100 crore test apply to a subsidiary of a listed company?
Not for that limb. Indian subsidiaries of companies listed in India are covered by limb (i) regardless of their own size.
What is the due date for AOC-4 XBRL?
Within 30 days of the annual general meeting at which the financial statements are adopted, as with AOC-4 under Section 137.
Do I need to attach a PDF to AOC-4 XBRL?
Yes, since the Amendment Rules, 2025 (in force 14 July 2025): a signed copy of the financial statements authenticated under Section 134, including the Board's report and auditors' report, in PDF format.
Which taxonomy should I use?
Annexure-II (AS, commercial and industrial) for companies under the Companies (Accounting Standards) Rules, and Annexure-II A for companies under the Ind AS Rules.
Check your own case
Run the XBRL applicability checker for a quick, documented answer, or start a CORAA trial to see how the reporting workflow fits your audit engagements.
Sources: Companies (Filing of Documents and Forms in XBRL) Rules, 2015 (Rule 3 as amended), reproduced at ca2013.com and ibclaw.in; Amendment Rules, 2025 at ibclaw.in. This is educational content, not professional advice.