On Oct. 9, 2025, IND CDSL said revised checklist for IAR is provided, applicable for internal/concurrent audit for half year ended Sep. 30, 2025.
For the half year ended Sep. 30, 2025, IAR must be filed by Nov. 15, 2025 online only; physical submissions will be treated as non-compliance.
If the same auditor handles both internal and concurrent audits, a consolidated report in annexure-A is required; if different auditors, IAR in annexure-A and CAR in annexure-B must be submitted.
On Oct. 21, IND CDSL issued revised checklist for concurrent audit.
IND CDSL issued a revised checklist for concurrent audit of depository participants' risk-prone areas, following Apr. 12 communique no. CDSL/A,I&C/DP/POLCY/2024/198.
Concurrent auditors must conduct daily 100% audit of designated risk areas, and the monthly audit reports will be due by the 10th day of the following month after audit.
Follows IND CDSL Apr. 2024 revised checklist for concurrent auditors, see #215363.
Also follows CDSL Oct. 18, 2024 amendments to DP penalty structure, see #230795.
Document dated Oct. 21, 2024, received from IND CDSL Oct. 22, summarized Oct. 25.
In addition to the above, other key audit areas include e-DIS processing and controls, transaction statement procedures, and account closure and transmission processes.
Notable Requirements
Verification of Aadhar KYC records with KRA, mandatory conversion of eligible accounts to Basic services demat account (BSDA), enhanced due diligence for Sikkim accounts.
Two-factor authentication for e-DIS processing and grievance redressal within 21 days.
Other requirements per revised checklist are provided for in document's annexure A.
Apr. 2025 Revised Format
On Apr. 8, 2025, IND CDSL said revised checklist for internal audit report (IAR) is provided, applicable for internal/concurrent audit for half year ended Mar. 31, 2025.
If same auditor conducts both audits, submit consolidated report in annexure-A format; if different auditors are appointed, submit the internal audit report in annexure-A and attach the concurrent audit report (CAR) in annexure-B format.
Due date for submission of IAR for the half year ended Mar. 31 2025 is May 15, 2025.
Submission of the IAR and CAR must be done online as per the procedure, physical submissions will not be accepted and will be considered non-submissions.
The audit report must include a declaration that at least one person conducting the audit holds a valid National Institute of Securities Markets (NISM) certification.
Reports signed by unqualified auditors will be rejected, deemed non-submissions.
Internal auditors must verify the proper implementation of online dispute resolution (ODR) mechanism by DPs and ensure all related website compliances are completed.
Sep. 2025 Revised Checklist
On Sep. 26, 2025, IND CDSL revised checklist for concurrent audit of depository participants' risk-prone areas using revised checklist in annexure A, introducing stricter timelines for KYC uploads, Aadhaar validation, and reassessment of BSDA eligibility.
Nomination rules are updated to align with IND SEBI’s Jun. 2024 circular (#215323) and require regular follow-ups with clients who have not submitted nominations.
New requirements are introduced for foreign portfolio investor (FPI) conditional registration, surveillance alerts standard operating procedure (SOP), and freeze/unfreeze notification systems.
Grievance resolution timelines are reduced from 30 to 21 days, and DPs must adopt SCORES 2.0.
Additional controls have been added for account closure and transmission on death.
The amendments to the checklist are effective from Oct. 1, 2025.
Oct. 2025 Revised Format
On Oct. 9, 2025, IND CDSL said revised checklist for IAR is provided, applicable for internal/concurrent audit for half year ended Sep. 30, 2025.
For the half year ended Sep. 30, 2025, IAR must be filed by Nov. 15, 2025 online only; physical submissions will be treated as non-compliance.
If the same auditor handles both internal and concurrent audits, a consolidated report in annexure-A is required; if different auditors, IAR in annexure-A and CAR in annexure-B must be submitted.
Regulators
IND CDSL
Entity Types
Auditor; B/D; Bank; Depo
Reference
Com CDSL/AUDIT/DP/POLCY/2025/684, 10/9/2025; Com CDSL/A,I&C/DP/POLCY/2025/652, 9/26/2025; Com CDSL/AUDIT/DP/POLCY/2025/234, 4/8/2025; Com CDSL/A,I&C/DP/POLCY/2024/627, 10/21/2024
