5 Things Your CA Won't Proactively Tell You Are Overdue

A good CA reliably files what's in their scope — your GST, TDS, and the annual returns they're engaged for. But a lot of compliance lives outside the monthly tax rhythm, and those items often go unwatched because nobody's job is to watch them. Here are five things founders assume are handled but frequently aren't: FEMA filings, event-triggered ROC forms, IP assignment, statutory registers, and evidence retention. None of this is a knock on your CA — it's a scope gap. The fix is seeing the whole picture, not just the tax slice.

Why this gap exists

Most CA engagements are built around recurring, predictable filings. That's exactly the work a monthly retainer is priced for. But compliance also includes event-driven obligations (a funding round, a foreign investor, a new contractor) and standing obligations (registers, IP, evidence) that don't generate a monthly task. They fall between the cracks not through negligence, but because they're nobody's default responsibility — and you, the founder, signed warranties that they're fine.

1. FEMA filings after foreign money

If you took foreign investment, FC-GPR (30 days) and the annual FLA are owed to the RBI — separate from anything your tax CA does monthly. These are among the most commonly missed and most serious in diligence.

2. Event-triggered ROC forms

A funding round triggers PAS-3 and possibly MGT-14; a director loan affects DPT-3; a deposit-like receipt has its own form. Your CS handles some of these — but only if they're told the event happened. The trigger is on you to surface.

3. IP assignment

Whether your founders, employees and contractors have assigned IP to the company is a legal matter, not a tax one — so it's outside a typical CA's remit, yet it's a top diligence red flag.

4. Statutory registers

The registers of members, directors, charges and SBO must be maintained under the Companies Act. They're easy to neglect because nothing prompts them — until an auditor or acquirer asks (statutory registers).

5. Evidence retention

Even where filings happen, the proof often lives only in your CA's inbox. If you can't produce the filed acknowledgement, you can't demonstrate compliance in diligence — see evidence, not 'filed'.

The point isn't to replace your CA — it's to see everything

Your CA is the person who files. What's missing is a single, independent view of everything that applies — tax and FEMA and ROC events and legal and the evidence — so the things outside the monthly rhythm don't quietly go overdue. That's the gap a system of record fills: it sits above your CA, shows the whole obligation set with owners and status, and keeps everyone (including your providers) accountable.

See the whole picture in one place

ComplianceStack shows your complete applicable compliance — across tax, payroll, ROC, FEMA and legal — with what's due, who owns it, whether it's done, and the evidence. Your CA keeps filing; you finally get to see if anything's slipping. Get your free compliance health check.