Compliance Monitoring Framework: After Approval: What Continues
Compliance Monitoring Framework does not end at approval — a set of obligations continues afterwards. The questions below are the ones raised most often in practice; the full scope of the service is on the Compliance Monitoring Framework page.
Is a Compliance Monitoring Framework a legal requirement?
There is no single section of law titled 'Compliance Monitoring Framework' that mandates this exact deliverable. However, Section 134(5) of the Companies Act 2013 requires directors to state that they have devised proper systems to ensure compliance with all applicable laws, and that those systems are adequate and operating effectively. For listed companies, SEBI LODR Regulation 17(3) requires the Board to periodically review compliance reports for all applicable laws and the steps taken to rectify instances of non-compliance, and Regulation 24A requires an Annual Secretarial Compliance Report. A formal framework is the practical mechanism through which these statutory representations are made honestly and defensibly.
In practice: ' The honest answer: the framework itself is not a named statutory form. The underlying obligation to have adequate compliance systems is very much mandatory, and without a framework, the directors' statement rests on hope rather than evidence.
Does PNPC sell compliance management software?
No. PNPC is a practising CA firm, not a software vendor. We configure and recommend a tracking tool appropriate to your scale — this could be a well-structured tracking workbook for a smaller company, or integration guidance for a third-party compliance management platform for a larger group — but the value we provide is the underlying Applicable Laws Assessment, the register design, the independent quarterly review, and the Audit Committee reporting. The tool is the container; the professional judgment behind what goes into it is the actual service.
In practice: A company can buy an expensive compliance software licence and populate it itself, incompletely, without an independent Applicable Laws Assessment underneath it. The software then gives false confidence — a clean dashboard that is only as complete as what was manually entered. We build the substance first.
Will the framework tell us about upcoming regulatory changes, or only track existing obligations?
Both. The quarterly PNPC review and the annual framework refresh specifically check for regulatory developments that affect the company — amended thresholds, new forms, changed due dates, or entirely new obligations (for example, the four Labour Codes, notified as effective from 21 November 2025, which bring changes to wage, PF/ESI and other labour-law compliance, with transition arrangements for the older Acts). The register is updated proactively rather than only after the company is caught out by a change it did not know about.
In practice: Regulatory change tracking is genuinely difficult to do well without a firm actively practising across these areas day to day — this is one dimension where a software-only tool, however well configured, cannot substitute for a CA firm's ongoing regulatory awareness.
Can the framework include contractual compliance obligations, not just statutory ones?
Yes, on request. Many companies have financial covenants under loan agreements, reporting obligations to investors under a Shareholders' Agreement, or specific undertakings in material customer contracts. These can be added as tracked items alongside statutory obligations in the same register, giving the Board and Audit Committee one consolidated view of everything the company has committed to, not only what the law requires.
In practice: Loan covenant breaches are a real and under-tracked risk for many private companies — a missed quarterly covenant certificate to a lender can trigger technical default clauses.
Is the compliance dashboard something the Board can access directly, or only PNPC and internal staff?
This is configured to the client's preference. Many clients want a summarised, Board-ready report presented at each Audit Committee meeting rather than raw dashboard access for every director; others prefer read-only dashboard access for Audit Committee members between meetings. We configure access levels — data entry, internal view-only, and Audit Committee/Board view — as part of the dashboard setup stage.
In practice: We generally recommend a curated quarterly report over raw dashboard access for the full Board — directors are better served by a synthesised risk view than by being handed an unfiltered spreadsheet to interpret themselves.
Does PNPC provide this service only to companies that are also its audit or tax clients?
No. While the framework naturally integrates well when PNPC also handles the underlying statutory audit, tax, or secretarial compliance work, we do build and independently review Compliance Monitoring Frameworks for companies whose day-to-day filings are handled by another firm. In those cases, we coordinate with the existing team rather than replacing them.
In practice: We do flag one practical point to prospective clients in this situation: independent review works best with genuine cooperation from the existing filing team, since we need visibility into their filing evidence to verify status. We set this expectation clearly at the outset.
What is the difference between a 'compliance calendar' and a 'Compliance Monitoring Framework'?
A compliance calendar is typically a list of known recurring due dates — GST returns, TDS returns, MCA annual filings — often maintained by the accounting or CA team as part of routine service. A Compliance Monitoring Framework is broader and more structured: it includes the comprehensive Applicable Laws Assessment (not just recurring known filings but also event-triggered and less-obvious obligations), documented ownership and escalation, independent quarterly verification, and formal Audit Committee/Board reporting. A calendar is a component that typically sits inside a full framework.
In practice: Many companies believe they already have 'compliance monitoring' because their CA firm sends deadline reminders. A reminder calendar is valuable but is not the same as a Board-facing governance system with independent verification and escalation — we make this distinction explicit during scoping so expectations are set correctly.
What if our company operates in a sector with unusually heavy regulatory obligations, like NBFCs or listed real estate (RERA)?
Sector-specific obligations — RBI regulatory returns and prudential norms for NBFCs, RERA project-wise compliance and quarterly progress reporting for real estate developers, SEBI intermediary regulations, or FSSAI licensing conditions for food businesses — are incorporated into the Applicable Laws Assessment as a distinct, specialised category, often requiring PNPC to work alongside the company's sector-specific compliance/legal advisor rather than covering that specialised regulatory area in isolation.
In practice: For heavily regulated sectors, we recommend the framework explicitly include the sector regulator's specific reporting calendar (RBI returns for NBFCs, RERA quarterly updates for developers) as a first-class category — bolting these on as an afterthought is a common design mistake we correct during scoping.
Is there a difference in approach for a family-owned private company versus a VC-funded startup?
The underlying legal obligations are largely the same, but the governance context differs. A VC-funded company typically has nominee directors, investor reporting covenants, and near-term funding or exit plans that raise the value of a documented, diligence-ready framework sooner. A family-owned private company may prioritise director-liability protection and succession-related compliance discipline. PNPC scopes the framework's emphasis — investor-reporting integration versus succession and continuity focus — to the company's actual governance context during the initial scoping conversation.
In practice: For a family business, a framework can specifically help a next-generation director who is inheriting compliance responsibility without having lived through the company's compliance history — the register itself becomes an onboarding tool for succession.
Where this sits in the wider engagement
Compliance Monitoring Framework rarely arrives on its own. The statutory basis and the current requirements are set out on the Compliance Monitoring Framework service page, and the related services are grouped under Corporate Law.
What PNPC does
PNPC Global has practised since 1986 across India and the UAE. On Compliance Monitoring Framework we take the work end to end — reviewing the facts, preparing and filing what is required, and dealing with the authority through to closure.