Chartered Accountants in India, working with clients across the USA

ICAI peer review, explained

Peer review in India: what audit firms and the companies they audit need to know

ICAI peer review checks whether an audit firm's work meets professional standards. A valid peer review certificate is now a requirement for auditing many entities in India. We help audit firms prepare for their review, and we explain what the certificate means for US companies choosing an auditor for their Indian subsidiary.

Overseen by
Peer Review Board of ICAI
Guidelines
Peer Review Guidelines, 2022
Quality standard
SQC 1 (SQM 1 and SQM 2 deferred)
Certificate
Valid for three years, in most cases

Peer review in India: how it works and how to prepare

Peer review is the process by which the Institute of Chartered Accountants of India (ICAI) checks the quality of assurance work done by Chartered Accountant firms, called practice units. An experienced Chartered Accountant from ICAI's panel of peer reviewers examines the firm's systems and a sample of its audit files, and reports to the Peer Review Board. If the review is satisfactory, the firm receives a peer review certificate.

What a peer review covers

The aim of peer review is to make sure that practice units follow the technical, professional and ethical standards that apply to audit and other assurance work. The reviewer looks at:

  • Compliance with the Standards on Auditing and other engagement standards issued by ICAI
  • The firm's system of quality control under SQC 1, including leadership, ethics, client acceptance, human resources, engagement performance and monitoring
  • Independence and ethical requirements under the ICAI Code of Ethics
  • Documentation of audit work, as required by SA 230
  • Compliance with laws and regulations that apply to the engagements reviewed

The review is about how the firm works, not about re-auditing the client's accounts. But because the reviewer reads real audit files, weak documentation in a statutory audit, tax audit or other assurance engagement shows up quickly.

Which engagements the reviewer looks at

The reviewer selects a sample from the practice unit's assurance engagements during the review period. The sample can include:

Firms with a mix of these engagements should make sure each type meets its own standard. For example, a risk control matrix and testing documentation support IFC reporting in statutory audits, while bank audits are checked against the lender's instructions and RBI requirements.

Who must hold a peer review certificate

ICAI has made peer review mandatory in phases. A practice unit covered by a phase must hold a valid peer review certificate before accepting the statutory audits that phase covers.

Summary of ICAI's peer review mandate. ICAI has revised the timing of some phases, so check the current announcement for your firm.
PhaseFromCovers
IApril 1, 2022Practice units auditing entities whose equity or debt securities are listed in India or abroad
IIApril 1, 2023Practice units auditing large unlisted public companies (by paid-up capital, turnover or borrowings), and attestation firms with five or more partners
IIIApril 1, 2024Practice units auditing entities that raised more than ₹50 crore from the public, banks or financial institutions, and public interest entities including certain trusts, and attestation firms with four or more partners
IVApril 1, 2025Practice units auditing branches of public sector banks, and attestation firms with three or more partners

Separately, SEBI's listing regulations require that the statutory auditor of a listed entity holds a valid peer review certificate. Banks, regulators and government bodies that appoint auditors often ask for one too.

SQC 1, SQM 1 and SQM 2

Quality control in Indian audit firms is governed by the Standard on Quality Control (SQC) 1. ICAI has issued two newer standards based on the international quality management standards: SQM 1, on quality management at firm level, and SQM 2, on engagement quality reviews. Their mandatory effective date has been deferred, and SQC 1 remains in force until ICAI announces otherwise.

SQC 1 (current)

  • Quality control system with six elements
  • Policies and procedures approach
  • Monitoring and inspection of files
  • Basis for current peer reviews

SQM 1 and SQM 2 (deferred)

  • Risk-based quality management system
  • Firm sets its own quality objectives and responses
  • Annual evaluation of the system
  • Separate standard for engagement quality reviews

How the peer review process works

  1. Application: the practice unit applies to the Peer Review Board and submits its questionnaire, declarations and list of assurance engagements.
  2. Appointment of reviewer: a reviewer from ICAI's panel is appointed for the practice unit.
  3. Sample selection: the reviewer selects a sample of engagements to examine, along with the firm's quality control documents.
  4. Review: the reviewer examines the firm's policies, files and records, on site or remotely, and discusses observations with the partners.
  5. Report: the reviewer reports to the Peer Review Board, which may issue a certificate, ask for improvements or require a follow-up review.
  6. Certificate: a satisfactory review results in a peer review certificate, generally valid for three years.

How we help practice units prepare

We support practice units in getting ready for their peer review. We do not carry out the review itself, which is done by the reviewer appointed under ICAI's process. Our readiness work includes:

  • Gap assessment: comparing your quality control policies with SQC 1 and the Peer Review Guidelines
  • Quality control manual: drafting or updating policies on independence, acceptance, consultation, engagement quality control review and monitoring
  • File reviews: reviewing a sample of audit files against the Standards on Auditing, as a reviewer would
  • Templates: engagement letters, independence declarations, planning memos, materiality workings and completion checklists
  • Training: sessions for partners and staff on documentation and common review findings
  • Remediation: fixing issues before the application is submitted

A practical 90-day readiness plan

  1. Days 1 to 15: list all assurance engagements in the review period, collect existing policies and identify the partners and staff involved.
  2. Days 16 to 40: compare policies with SQC 1, update the quality control manual and collect independence declarations for the period.
  3. Days 41 to 70: review a sample of engagement files across statutory audits, tax audits and bank audits, and record the gaps.
  4. Days 71 to 85: fix the gaps that can still be fixed, such as missing documentation of reviews already performed, and train the team on the rest.
  5. Days 86 to 90: complete the application documents and keep a clear index of policies and files ready for the reviewer.

Gaps found in past files cannot be hidden, and documents must never be back-dated. The aim is to understand the gaps, explain them honestly and show that the firm's systems have improved.

Common peer review findings

  • Engagement letters missing or not updated for the year
  • Independence declarations not obtained from all staff on the engagement
  • No documented materiality or risk assessment
  • Audit procedures performed but not documented, or documented after the report date
  • Management representation letters not dated close to the report date
  • No evidence of engagement quality control review where required
  • Working papers not archived within the required period after the report date

Getting audit documentation right

Most peer review comments come down to documentation. Under SA 230, the audit file must show what was done, the evidence obtained and the conclusions reached, in enough detail for an experienced auditor with no previous involvement to understand it.

  1. Plan in writing: engagement letter, independence confirmations, risk assessment and materiality before fieldwork starts.
  2. Link work to risks: each significant risk should lead to specific procedures and a documented conclusion.
  3. Record review: show who prepared and who reviewed each working paper, and when.
  4. Close properly: management representations, subsequent events and a completion checklist dated before the report.
  5. Assemble on time: under SQC 1, the final engagement file should ordinarily be assembled within 60 days of the report date, and nothing should be deleted afterwards.

Firms that also carry out forensic engagements under FAIS should apply the same discipline to evidence and working papers.

What peer review means for companies and US parents

Peer review sits alongside two other layers of oversight in India: the Quality Review Board, which reviews the quality of audit services for certain companies, and the National Financial Reporting Authority (NFRA), which oversees audits of listed and other large companies.

Who this page and our readiness support are for

Audit firms preparing for review, and companies that rely on their work.

  • Audit firms auditing listed entities

    Practice units that need a certificate before accepting listed company audits.

  • Growing CA firms

    Firms with three or more partners now covered by the mandate.

  • Firms auditing banks and large entities

    Practice units auditing public sector bank branches or entities above the thresholds.

  • Companies and US parents

    Businesses checking that their Indian auditor meets the requirement.

How our readiness support works

A practical programme to get your practice unit ready before you apply.

  1. 1

    Understand your practice

    We review your structure, engagements and current quality control documents.

  2. 2

    Gap assessment

    We compare your policies and files with SQC 1 and the Peer Review Guidelines.

  3. 3

    Mock file review

    We review a sample of engagement files as a reviewer would and list the gaps.

  4. 4

    Fix and train

    We help update policies and templates and train partners and staff.

  5. 5

    Ready to apply

    You submit your application with your documents in order.

Documents we review for readiness

  • Quality control manual or policies
  • Independence declarations
  • Engagement letters
  • List of assurance engagements
  • Sample audit files
  • Training records
  • Engagement quality control review records
  • Monitoring and inspection reports
  • Previous peer review report, if any
  • Client acceptance and continuance forms

What you receive

  • Gap assessment against SQC 1 and the guidelines
  • Updated quality control policies and templates
  • File review findings with fixes
  • Training for partners and staff
  • Checklist for the peer review application
  • Roadmap for moving to SQM 1 and SQM 2

Peer review questions

General guidance only. Rules change and every case is different, so please speak to us before acting on it.

Ask a question

A peer reviewer is an experienced Chartered Accountant on ICAI's panel who reviews another practice unit's quality control systems and a sample of its assurance files, and reports to the Peer Review Board.

Yes, for practice units covered by ICAI's phased mandate, such as auditors of listed entities, large unlisted public companies and certain other entities, and attestation firms above a partner count. SEBI also requires the auditor of a listed entity to hold a valid certificate.

A peer review certificate is generally valid for three years, after which the practice unit needs a fresh review to continue the covered audits.

Not yet. ICAI has issued SQM 1 and SQM 2, but their mandatory effective date has been deferred. SQC 1 remains in force until ICAI announces otherwise.

No. Peer reviews are carried out by reviewers appointed under ICAI's process. We help practice units prepare for their review.

The Peer Review Board may ask the practice unit to make improvements and may require a follow-up review before issuing a certificate.

ICAI publishes a list of practice units holding valid peer review certificates on its website. You can also ask the firm for a copy of its certificate.

Not directly. It looks at how the audit firm carried out and documented its work. It does not re-audit the client's financial statements.

Get your practice unit ready for peer review

Tell us about your firm, your engagements and when you plan to apply. We'll set out a readiness plan that fits your timeline.

This page is general information about audit and assurance requirements in India and is not professional advice for your situation. Thresholds, forms and due dates change; please confirm the position for your entity before acting.