As per the Proviso to Rule 3(1) of Companies (Accounts) Rules, 2014 for the financial year commencing on or after the 1st day of April 2023, every company that uses accounting software for maintaining its books of account, shall use only such accounting software which has a feature of recording audit trail of each transaction, creating an edit log of each change made in the books of account along with the date when such changes were made and ensuring that the audit trail cannot be disabled.

Guidance issued by the ICAI on the amendment:

• The amendments require every company that uses accounting software to use such software that has a feature of audit trail that cannot be disabled.

• The management has a responsibility for the effective implementation of the requirements prescribed by account rules i.e., every company that uses accounting software for maintaining its books of account, should use only such accounting software that has the following features:

  • Records an audit trail of each transaction, creating an edit log of each change made in the books of account along with the date when such changes were made; and Ensuring that the audit trail is not disabled.

  • Thus, it is the management, who is primarily responsible for ensuring the selection of the appropriate accounting software for ensuring compliance with applicable laws and regulations (including those related to the retention of audit logs).

• Ensure that the audit trail captures the changes to each transaction of books of account; information that needs to be captured may include the following:

  • when were the changes made,

  • who made those changes,

  • what data was changed, etc.

• For example, the creation of a user in the accounting software may be understood as a transaction in the software. However, creating a user account in the accounting software would not change the records of books of account as defined in Section 2(13) of the Act. But adding a new journal entry or changing an existing journal entry will be seen as a change made to the books of accounts.

Compliance by Ginesys

• The Ginesys ERP has the feature of audit trail in the application that covers multiple modules. In our application it is module-wise, so once the entity enables the audit trail for any of the mandatory modules (i.e. the modules that impact the Books of accounts), the system does not allow anyone to disable it.

• For the ease of the Entity, with the version release 12.17.2 audit trailing turns auto-enabled on all the mandatory modules (i.e. the modules that impact the Books of accounts) for entities having CIN updated in the ERP.

• The audit trailing records when, who, and what for every such transaction to ensure full compliance and visibility.
  Note: The logs are saved in the database tables, and they will increase each passing day which may impact the performance of the system.

• We have also given an option to enable audit for other operational modules that do not have any impact on the books of accounts. Still, the entity should consider database size and performance before taking any call on these aspects.

• Display of electronic records in legible format - The audit trail of transactions can be viewed from the separate menu and the option to export into .xlsx format is also available.

Please find attached the FAQ link for further details:

Audit Trail New (post 12.17.2)

Enabling Audit trail (post 12.17.2)

Audit Trail FAQs (New)

To know more about Audit trail in general -

https://ginesys.atlassian.net/wiki/spaces/PUB/pages/1760886915