CARO applicability to companies in Group

Subsidiaries: Any private company that is a subsidiary or holding of a public company is not eligible for the CARO exemption reserved for independent private companies, regardless of its size.

Annual Applicability: CARO applicability is not a "once applicable, always applicable" rule. It must be reassessed each financial year. If a company qualifies as a "Small Company" in a later year (and is not a subsidiary of a public company), it will become exempt again for that year.