CORAA

Whistleblower / Vigil Mechanism Review Checklist — Section 177

Tests whether the vigil mechanism required under Section 177(9)-(10) of the Companies Act 2013 is designed and operating — policy existence, direct access to the audit committee chair, protection against victimisation, and complaint tracking.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Standard
Sec 177(9)-(10), Companies Act 2013
Mandatory for
Listed cos; deposit-taking cos; borrowings > ₹50 cr
Key test
Direct access to Audit Committee chair
Format
Microsoft Word (.docx)
Share this template
Your firm — letterhead
Appears at the top of the document as the audit firm letterhead.
Used as the letterhead block.
Engagement details
The client and period this document is for.
What’s inside

An excerpt from the template.

VIGIL MECHANISM / WHISTLEBLOWER POLICY — REVIEW CHECKLIST

Entity: ___ · Period: ___

Scope: tests whether the vigil mechanism required under Section 177(9)-(10) of the Companies Act 2013 and Rule 7 of the Companies (Meetings of Board and its Powers) Rules 2014 is designed and operating as required. Mandatory for listed companies, companies accepting deposits from the public, and companies with borrowings from banks/public financial institutions exceeding ₹50 crore — verify applicability to this entity before relying on this checklist.

Conclusion

↑ Excerpt only — the full template is what you download as Word
About this template

What you’re downloading, and when to use it.

This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

Everything is generated in your browser and on a stateless API endpoint — no account, nothing stored on our servers. We’ll ask for a work email once before your first download so we can send you the file and the occasional relevant update; after that, downloads on this device are instant. Edit freely in Word, Google Docs or Pages before sending to your client.

Common questions

FAQs.

Which companies are legally required to have a vigil mechanism?
Section 177(9) requires it for every listed company, every company that accepts deposits from the public, and every company that has borrowed money from banks or public financial institutions in excess of ₹50 crore. Other companies may adopt one voluntarily, but this checklist's mandatory-compliance framing applies specifically to entities meeting one of these three tests.
What does "direct access to the Audit Committee chairperson" mean in practice?
The second proviso to Sec 177(9) requires that in exceptional cases the vigil mechanism must allow a complainant to approach the Audit Committee chairperson directly, bypassing the normal reporting hierarchy — the checklist tests whether the actual policy document and complaint-routing process provide for this, not just whether a general grievance channel exists.
What happens if a complaint reveals retaliation against the whistleblower?
The policy itself should prescribe a disciplinary process for anyone found to have victimised a whistleblower — the checklist tests whether this protection is documented and has actually been invoked where relevant, since a policy that is silent on enforcement against retaliation provides protection in name only.
Related templates

You might also need.

Engagement Quality Control Review (EQCR) Process — ICAI Audit Working Paper
Free engagement quality control review (eqcr) process audit working paper template (ICAI, Chapter 6). Generate
Internal Audit Charter Template — Section 138 / IIA / SIA
Free Internal Audit Charter template for Indian companies under Section 138 of the Companies Act 2013. IIA / I
Fraud Risk Assessment (SA 240) — ICAI Audit Working Paper
Free fraud risk assessment (sa 240) audit working paper template (ICAI, Chapter 2). Generate with your firm le