The Bureau of Energy Efficiency (BEE) issued draft regulations on 15th April, 2021 related to the manner and intervals for conduct of energy audit (Accounting) in electricity distribution companies (DISCOMs) and requested public comments. The primary objective of these regulations is to measure and verify the DISCOMs’ compliance with the targets on Transmission and Distribution (T&D) losses notified to them under the Perform, Achieve, and Trade (PAT) scheme. However, DISCOMs can also be mandated to use the data from the detailed energy audit conducted under these regulations for all their regulatory fillings mandated under the Electricity Act, 2003. There should not be any inconsistency between the data submitted by the DISCOMs to different authorities. Our comments/suggestions have been grouped into two sets. The first set of comments are related to improving the process of conducting energy audits through increased transparency and accountability. The second set of comments are related to comprehensive recording of the data through different data forms and providing clear definitions and methodology to ensure accurate reporting of T&D losses. Both set of comments take into account the current practices employed by the DISCOMs on data collection and T&D loss estimation.