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Resources - Statutory Compliance Audit

Statutory and tax compliance internal audit checklist.

Compliance audit is not just due-date tracking. A strong review tests the control system behind GST, TDS/TCS, income-tax forms, ROC filings, payroll statutory payments, licences, notices, portal access and evidence retention.

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Ten statutory and tax compliance areas to test areas

Compliance universe and ownership

Risk: Applicable registrations, filings, licences or owners are incomplete, leading to missed returns or unassigned compliance risk.

Controls
  • Compliance universe register
  • Owner matrix
  • Applicability review
  • Compliance calendar
Tests
  • Compare registrations to entity activities and locations
  • Review owner sign-offs
  • Check new entity/location/product triggers
  • Inspect overdue items and escalation trail
Evidence

Entity structure, registrations, licences, compliance calendar, owner matrix, board/audit committee updates and overdue tracker.

GST outward supply and return filing

Risk: Sales, credit notes, export supplies, e-invoices or GSTR-1/3B values are incomplete, late or inconsistent.

Controls
  • Invoice sequence control
  • E-invoice/e-way bill review
  • GSTR-1 to 3B reconciliation
  • Return approval
Tests
  • Reconcile sales register to GSTR-1 and 3B
  • Test cancelled/credit-note sequences
  • Inspect e-invoice/e-way bill exceptions
  • Check filing dates and reviewer evidence
Evidence

Sales register, GST returns, e-invoice data, e-way bills, credit-note register, challans and reviewer sign-off.

GST input tax credit and reversals

Risk: ITC is availed without vendor reporting, eligibility review, blocked-credit screening or Rule 42/43 reversal support.

Controls
  • GSTR-2B reconciliation
  • Blocked-credit checklist
  • Vendor follow-up
  • ITC reversal working
Tests
  • Match purchase register to GSTR-2B
  • Test blocked-credit categories
  • Review unmatched ITC ageing
  • Check reversal and re-availment approvals
Evidence

Purchase register, GSTR-2B, vendor confirmations, blocked-credit working, Rule 42/43 computation and reversal entries.

GST payments, refunds and notices

Risk: GST liability, interest, late fees, refunds or notices are not computed, paid, responded to or tracked completely.

Controls
  • Liability review
  • Challan approval
  • Refund support file
  • Notice tracker
Tests
  • Agree liability to challans and cash/credit ledger
  • Review interest/late fee working
  • Inspect refund support
  • Age open notices and responses
Evidence

GST ledgers, challans, interest workings, refund applications, notices/orders, response files and legal/advisor correspondence.

TDS/TCS deduction, deposit and returns

Risk: Withholding is missed, applied at wrong rate, deposited late, filed under wrong form/section or unreconciled to books.

Controls
  • Payment-code mapping
  • TDS/TCS rate review
  • Monthly challan reconciliation
  • Quarterly return review
Tests
  • Sample payments for TDS/TCS applicability
  • Reconcile GL to challans and returns
  • Test lower/nil certificates
  • Review return filing and correction statements
Evidence

Vendor/customer ledgers, TDS/TCS workings, challans, Form 24Q/26Q/27Q/27EQ or current equivalent forms, certificates and TRACES reports.

Income-tax forms, advance tax and tax audit tie-outs

Risk: Advance tax, self-assessment tax, statutory forms, Form 3CD data or tax-audit schedules are late, unsupported or inconsistent.

Controls
  • Tax calendar
  • Computation review
  • Form filing tracker
  • Tax audit tie-out
Tests
  • Review advance-tax computation and challans
  • Check statutory form filing evidence
  • Tie Form 3CD clauses to ledgers
  • Inspect management certification
Evidence

Tax computations, challans, income-tax portal acknowledgements, Form 3CD workpapers, ICDS/allowance workings and management representations.

ROC and Companies Act filings

Risk: Board/shareholder filings, annual forms, resolutions, registers or event-based forms are delayed, incomplete or inconsistent with books.

Controls
  • ROC calendar
  • Secretarial event tracker
  • Register maintenance
  • Form approval workflow
Tests
  • Match board events to filed forms
  • Inspect AOC-4/MGT-7 and event forms
  • Check additional fee/delay cases
  • Review register and minutes evidence
Evidence

MCA challans/SRN acknowledgements, board minutes, registers, annual return, financial statements, event tracker and secretarial certificates.

Payroll statutory compliance

Risk: PF, ESI, professional tax, labour welfare fund, gratuity or salary TDS compliance is inaccurate, late or unreconciled to payroll books.

Controls
  • Payroll compliance calendar
  • Payroll-to-challan reconciliation
  • Employee master review
  • Return approval
Tests
  • Reconcile payroll to PF/ESI/PT/TDS challans
  • Sample employee eligibility and wage base
  • Review late payment interest/damages
  • Check leaver and new joiner coverage
Evidence

Payroll register, employee master, PF/ESI returns, professional-tax challans, salary TDS returns, gratuity/leave workings and HRMS reports.

Portal access, maker-checker and audit trail

Risk: GST, income-tax, MCA, PF/ESI or licence portals are accessed through shared IDs, leavers, unreviewed DSCs or weak approvals.

Controls
  • Portal user register
  • DSC custody control
  • Maker-checker filing
  • Quarterly access review
Tests
  • Review active users and leavers
  • Inspect DSC/token custody
  • Check maker/checker evidence
  • Review filing audit trail and IP/user logs where available
Evidence

Portal users, DSC register, access review, leaver list, filing approvals, OTP/authorisation trail and consultant access list.

Notices, litigation and consultant management

Risk: Tax notices, assessments, appeals, consultant filings or management positions are not tracked, reviewed or escalated.

Controls
  • Notice register
  • Response approval
  • Litigation tracker
  • Consultant scope and SLA
Tests
  • Age notices and hearing dates
  • Review response quality and approvals
  • Tie disputed demands to books
  • Inspect consultant deliverables and pending list
Evidence

Notice register, portal notices/orders, response submissions, demand register, appeal files, consultant engagement letters and status MIS.

Monitoring

Turn compliance testing into recurring checks rules

GST return variance

GSTR-1, GSTR-3B, e-invoice, e-way bill, sales register or GL values differ beyond tolerance.

Unmatched ITC ageing

Purchase ITC is booked but missing from GSTR-2B or unreconciled beyond the approved ageing threshold.

TDS challan mismatch

TDS/TCS payable GL, deduction working, challan and return values do not agree by section/form.

ROC event not filed

Board/shareholder/capital/director event exists in minutes or registers but related MCA filing evidence is absent.

Payroll statutory shortfall

PF/ESI/PT/salary TDS challans do not reconcile with payroll, headcount or employee master changes.

Open notice ageing

Tax, GST, MCA, PF/ESI or licence notice remains open beyond internal response threshold or next hearing date.

Authority

Use with current official criteria sources

Use ICAI Standards on Internal Audit for scope, evidence, documentation and reporting. Verify current GST, Income-tax, MCA, PF/ESI, professional-tax, labour welfare fund and local licence requirements from official portals for the entity, period and state before reporting an exception.

ICAI IASB - Compendium of Standards on Internal Audit ->GST Portal - GSTR-3B user guide and FAQs ->GST Portal - GSTR-9 annual return manual ->Income Tax Department - TDS compliance FAQs ->Ministry of Corporate Affairs - Companies Act e-book ->EPFO - Circulars and employer compliance updates ->
FAQ

Statutory compliance audit FAQs questions

What is statutory compliance internal audit?

Statutory compliance internal audit reviews whether applicable GST, TDS/TCS, income tax, ROC, payroll statutory, licence, notice and portal-access obligations are identified, owned, filed, paid, reconciled, evidenced and escalated on time.

Is this a due-date calendar?

No. A calendar says when a return is due. This checklist tests whether ownership, registers, reconciliations, challans, filings, notices, approvals and evidence are strong enough to prevent missed or wrong compliance.

Which compliance areas should be continuously monitored?

High-value monitoring rules include GST return variances, unmatched ITC ageing, TDS challan mismatches, MCA event filings, payroll statutory shortfalls, leaver portal access and ageing notices.

Is this legal or tax advice?

No. It is an internal-audit workpaper starter. Verify current law, rules, notifications, portal behaviour, due dates, forms and entity-specific applicability before finalising scope or observations.