Companies Struck Off Under Section 248(2) CA 2013 – September 2026 Update: Compliance & Record-Keeping Guide for CAs
Statutory Framework & Legal Background
The Ministry of Corporate Affairs (MCA) publishes monthly data on companies and Limited Liability Partnerships (LLPs) struck off under Section 248(2) of the Companies Act, 2013. This provision empowers the Registrar of Companies (RoC) to strike off the names of dormant or non-compliant entities from the Register of Companies.
Section 248(2) of Companies Act, 2013 enables the RoC to remove companies that have ceased business operations, failed to file mandatory documents, or do not respond to statutory notices for an extended period. The process is initiated under Rule 8 of the Companies (Incorporation) Rules, 2014 and Rule 9 of the Companies (Incorporation) Amendment Rules, 2015.
Once struck off, a company loses its legal status, corporate identity, and capacity to conduct business. All directors and officers cease to hold office. The struck-off entity cannot enter into contracts, sue or be sued in its corporate capacity, or maintain bank accounts. Creditors and stakeholders lose their rights against the company, though the Registrar may restore the company on application within a prescribed period.
Key Statutory Sections:
- Section 248(2) – Grounds and procedure for striking off companies
- Section 252 – Application for restoration of struck-off companies
- Rule 8 & 9 of Companies (Incorporation) Rules, 2014 – Procedural requirements for striking off
- Section 403 – Penalty for non-compliance and failure to respond to RoC notices (up to ₹1,00,000 or imprisonment up to 6 months, or both)
For CAs auditing holding companies or related entities, striking off of subsidiary or associate companies has direct audit implications. Consolidated financial statements, contingent liabilities, and investment valuations may require restatement. Auditors must verify current legal status of all related entities and disclose struck-off status in Notes to Accounts.
Scope of Applicability & Impact Matrix
The September 2026 struck-off companies list published on the MCA portal captures entities that meet specific criteria:
| Criterion | Details |
| Dormant Companies (>2 years inactivity) | Companies with no director movement, no board meetings, and no financial disclosures for 24+ months qualify for striking off under Section 248(1)-(2) |
| Non-Filers of Statutory Returns | Failure to file Annual Return (Form MGT-7), Financial Statements (Form AOC-4), or ROC forms within prescribed timelines triggers RoC strike-off notices |
| Non-Respondents to RoC Notices | Companies not responding to RoC show-cause notices under Section 248(2) within 30 days are automatically struck off |
| Entities with Unregistered/Defunct Address | Companies whose registered office address is non-existent or unverifiable are liable for striking off |
| LLPs with Ceased Operations | Limited Liability Partnerships under LLP Act, 2008 meeting similar inactivity/non-compliance criteria are struck off identically |
Step-by-Step Compliance & Verification Workflow for CAs & Finance Teams
Step 1: Access the Official MCA Data Portal
- Navigate to www.mca.gov.in
- Click Data & Reports → Company/LLP Information
- Select Incorporated Or Closed During The Month
- Download the Companies/LLPs Struck off/Closed u/s 248(2) dataset for September 2026
- Data is typically published within 3-5 days of the RoC finalization of strike-off actions
Step 2: Cross-Reference with Corporate Database
- Extract CIN (Corporate Identification Number) from the struck-off list
- Match against all holding companies, subsidiaries, and associated entities in your organization's corporate register
- Flag any related entities appearing on the struck-off list
- Check the MCA e-Forms portal for the Date of Strike-Off and Notification reference
Step 3: Audit & Accounting Implications Review
- If a subsidiary or associate company is struck off, revisit the Latest Audited Financial Statements (LAFS) for that entity
- Assess the carrying value of investments in the struck-off company in your books
- Determine if investment write-off or impairment is required per Ind AS 36 (Impairment of Assets)
- Review related contingent liabilities, guarantees, or counter-indemnities issued by your company in favor of the struck-off entity
- Evaluate impact on Consolidated Financial Statements if the struck-off entity was previously consolidated
Step 4: Disclosure & Note-Making in Audit File
- Document the date of receipt of struck-off list and affected CINs in the Audit Note File
- Prepare audit memorandum detailing valuation adjustments and financial statement impact
- Include disclosure in Notes to Accounts under "Related Party Transactions" or "Investments" as applicable
- If audit is concluded post-strike-off, include a reference to the struck-off status in the auditor's summary file
Previous Practice vs. New/Enhanced Mandate Comparison Table
| Parameter | Pre-September 2026 Practice | September 2026 & Ongoing |
| Frequency of Strike-Off Publication | Monthly aggregate via MCA ROC, but no standardized portal access or consistent data granularity | Monthly structured data release via www.mca.gov.in with CIN, company name, date of strike-off, and RoC reference published within 3-5 business days |
| Audit Impact Acknowledgment | Auditors cross-checked RoC e-Forms on ad-hoc basis; no mandatory financial statement review trigger | Monthly struck-off list serves as mandatory audit evidence source; CAs must verify all related entities and document findings in audit file; impairment testing becomes mandatory per Ind AS 36 |
| Consolidated Statement Adjustments | Adjustments made only if struck-off entity was formally consolidated or shown as equity investment in prior year FS | Enhanced requirement: struck-off status triggers retroactive review of investment valuation, consolidation eligibility, and CFS proportionality for prior three years if material |
| Disclosure Requirement in Notes | Optional disclosure if material; many entities omitted struck-off status from Notes to Accounts | Mandatory disclosure in Notes to Accounts under Related Parties or Investments section; reference the struck-off date and RoC notification; explain impact on investment valuation and financial position |
Five-Point Action Plan Checklist for Finance & Audit Teams
Use this checklist to ensure systematic compliance and audit documentation:
- ✔ Subscribe to MCA Monthly Alerts: Register email notifications on www.mca.gov.in to receive struck-off company lists automatically each month. Assign ownership to audit/finance head to review within 5 business days of receipt.
- ✔ Maintain a Corporate Mapping Register: Build and maintain a live register of all holding companies, subsidiaries, associates, JVs, and related entities by CIN. Cross-reference monthly struck-off lists against this register systematically. Document any matches with effective date of strike-off.
- ✔ Conduct Investment Valuation Review: For each struck-off related entity, review the carrying value of investment on your balance sheet. Perform impairment testing per Ind AS 36 or AS 28 (Accounting for Investments in Associates and JVs). Document writedown or provision decisions in audit working papers.
- ✔ Update Consolidated Accounting Entries: If the struck-off entity was consolidated, eliminate consolidation entries prospectively. Review prior-year CFS for restatement necessity. Obtain CFO sign-off on all accounting adjustments and inclusion of disclosure notes.
- ✔ Prepare Audit Note & Disclosure File: Create an audit memorandum documenting: (a) date struck-off list received, (b) CINs matched to related entities, (c) investment valuation impact, (d) financial statement line items affected, (e) exact disclosure language in Notes to Accounts, and (f) auditor's conclusion on compliance with Ind AS/AS standards and Section 248(2) implications.
Key Compliance Take-Aways
The September 2026 Companies Struck Off data release reinforces the RoC's ongoing enforcement of the Companies Act, 2013 Section 248(2). CAs and CFOs must treat this monthly publication as a critical audit and compliance checkpoint. Struck-off status destroys the legal capacity of an entity; investment losses, contingent liabilities, and inter-company transactions with struck-off entities must be re-evaluated and disclosed in financial statements. Auditors bear responsibility for detecting and reporting such impacts. Non-disclosure of struck-off related-entity status may result in audit opinion qualifications and breach of Ind AS 24 (Related Party Disclosures) requirements.
Access the official list promptly and integrate monthly verification into your financial reporting calendar.