Schedule III amendment 2021: every change for Division I companies, in one table

The Schedule III amendment 2021 is the Ministry of Corporate Affairs notification G.S.R. 207(E) dated 24 March 2021, which amended Schedule III (often written Schedule 3) to the Companies Act, 2013 with effect from 1 April 2021. It amended all three Divisions: Division I (companies following the Accounting Standards), Division II (Ind AS companies) and Division III (Ind AS NBFCs). This article covers Division I only. It lists every change the notification made, with the old and new wording and where each one sits, then explains what it means for FY 2025-26 files. Each row links to the detailed guide for that item. For the full format, start with our Schedule III guide.

Schedule III amendment 2021 at a glance

The notification is short but dense. For Division I it does five things:

• changes two words in the rounding off instruction;
• renames the PPE heading on the face of the balance sheet and its note;
• moves two items (current maturities of long-term borrowings and security deposits) and adds new tables to existing notes;
• inserts heading Y, Additional Regulatory Information, with fourteen items, and a new heading VA, and omits heading X (the 2016 Specified Bank Notes disclosure);
• renames Total Revenue on the Statement of Profit and Loss and adds four items to its instructions.

Two earlier amendments are often confused with it. The split of trade payables into dues of micro and small enterprises and others, with the MSME note (heading FA), came from G.S.R. 679(E) of 4 September 2015. "Fixed assets" became "Property, Plant and Equipment" through G.S.R. 1022(E) of 11 October 2018. Neither is part of the 2021 changes, but the 2021 ageing table builds on the 2015 MSME split.

Every Division I change, in one table

References are to the Division I text as amended: "para" for the general instructions, letters for the notes in the General Instructions for Preparation of Balance Sheet (paragraph 6), and Roman numerals for the Statement of Profit and Loss.

The 14 new disclosures under heading Y

Heading Y is where most of the new disclosures sit. Most are "where applicable" items; the ratios apply to every company.

Each item, with formats, sample nil wording and the matching CARO 2020 clause, is in our guide to additional regulatory information under Schedule III. The ratios, with formulas, are in Schedule III ratios and the 25% variance.

Worked example: the two items that moved

The two reclassifications are the ones most often left in the old place in a rolled-forward Excel template. Take a company with a term loan of ₹60.00 lakh at 31 March 2026, of which ₹12.00 lakh is repayable within twelve months, a cash credit of ₹35.00 lakh, and electricity and rent deposits of ₹4.50 lakh that are not expected to be recovered within twelve months.

Long-term borrowings show ₹48.00 lakh (₹60.00 less ₹12.00). Other current liabilities no longer carry a "current maturities of long-term debt" line, and long-term loans and advances no longer carry security deposits. The amendment changed only the non-current heads (L and M). Short-term loans and advances (note R) were not amended, so treat a deposit recoverable within twelve months under the usual current/non-current tests.

Because the ratios use these figures, the move also matters there: current maturities now sit inside short-term borrowings, which is current liabilities, so the current ratio and the net capital turnover ratio (which uses working capital) should be computed on the reclassified figures for both years.

The new tables, and what they look like

The new formats that take the most work in a small-company file are the ageing tables and promoters' shareholding. An illustrative promoters' note, for a company with 10,00,000 equity shares where one promoter sold shares to the other during the year:

The Schedule says the % change is computed on the number of shares at the beginning of the year (or on the date of issue, for shares issued for the first time during the year): Mr. A went from 5,00,000 to 6,00,000 (+20%), Mrs. B from 5,00,000 to 4,00,000 (-20%). "Promoter" has its meaning under the Companies Act, 2013. ICAI's Guidance Note also suggests adding the number and percentage of shares at the beginning of the year as extra columns. More on this in the share capital note.

For ageing, receivables are aged in five buckets and payables in four, both from the due date of payment (from the transaction date where no due date is specified), with unbilled dues shown separately. The payables table has MSME and disputed MSME rows, so it must agree with the MSME split on the face. The CWIP ageing total must tally with CWIP in the balance sheet.

What the 2021 amendment means for FY 2025-26 files

The amendment applied from financial years beginning on or after 1 April 2021, so FY 2025-26 is its fifth year. ICAI's Guidance Note on Division I (Revised January 2022) confirms that comparatives are needed and should be prepared on the same lines as the current year. In practice that means:

• No transition relief left. FY 2024-25 comparatives should already be in the amended format. If last year's signed accounts were not (for example, ageing missing, or current maturities still in other current liabilities), the comparatives need regrouping, and a note saying the previous year figures have been regrouped is the usual practice.
• No later amendment to Division I. In India Code's amended text, the latest footnote to any Division I item is G.S.R. 207(E). We found no MCA notification amending Division I after it.
• Small companies are not exempt. Schedule III has no small-company exemption for these items. Small company status changes CARO and the cash flow statement, not the 2021 disclosures.
• Rounding is mandatory. The Guidance Note (para 6.15) says a company cannot continue to show full figures. A company with Total Income below ₹100 crore picks hundreds, thousands, lakhs or millions and uses that unit throughout.
• Undisclosed income still cites the 1961 Act. Para 5(ix) refers to tax assessments under the Income Tax Act, 1961. For FY 2025-26 that is still the law for assessments (section 536 of the Income-tax Act, 2025 keeps proceedings for earlier years under the 1961 Act); the 2025 Act applies from tax year 2026-27, and Schedule III has not yet been amended to refer to it.
• Old templates give themselves away. "Total Revenue", "Tangible assets", a "receivables outstanding for more than six months" line, or security deposits under long-term loans and advances all mean a pre-2021 template is still in use. It is worth checking each statement for these before review.

For a line-by-line review of the whole format, use our Schedule III compliance checklist. For the MSME side of the payables ageing and the tax disallowance, see MSME dues and section 43B(h).

What the same notification did to Divisions II and III

G.S.R. 207(E) made parallel changes for Ind AS companies, which are not covered here. In Division II it also substituted "Total Income" for "Turnover", inserted lease liabilities as a separate line under financial liabilities, replaced the statement of changes in equity format, and added an ageing schedule for receivables in Ind AS terms (credit risk and credit impaired, not "considered good / doubtful"). If a client has moved to Ind AS, use the Division II text, not this table. See Schedule III Division I, II and III.

Frequently asked questions

Sources

• MCA — G.S.R. 207(E), 24 March 2021, amendments to Schedule III (Gazette of India)
• Companies Act, 2013 — Schedule III Division I, as amended, with footnotes (India Code)
• ICAI — Guidance Note on Division I – Non Ind AS Schedule III to the Companies Act, 2013 (Revised January 2022), paras 3.1–3.2, 6.5 and 6.15

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