Secretarial Audit in 2026: what changed, and who is now inside the net
3 August 2026 8 min read Updated for FY 2025-26 Secretarial audit used to be a quiet annexure to the Board's report. It is not quiet any more. With effect from 1 April 2025, SEBI rebuilt regulation 24A of the Listing Regulations: the secretarial auditor of a listed company is now appointed by the shareholders, holds office for a fixed term, must hold a valid peer review certificate, and is barred from a list of other services. Separately, a limb of the Companies Act threshold that most people still read as a public company test in fact catches private companies too. This note sets out where the line now runs. In short Three thresholds under Rule 9. Paid-up capital of ₹50 crore or turnover of ₹250 crore catch a public company. Bank or public financial institution borrowings of ₹100 crore catch any company, private ones included. Regulation 24A was rebuilt by the SEBI (LODR) (Third Amendment) Regulations, 2024, effective 1 April 2025, with the detai...