Proposed ICAI Guidelines for Overseas CA Networks: Public Comments Open Until June 27, 2025

The Institute of Chartered Accountants of India (ICAI), through its Committee for Aggregation of CA Firms (CACAF), has issued an Exposure Draft of proposed guidelines for “Overseas Networks” to invite public comments by June 27, 2025. These guidelines aim to regulate and promote cross-border collaborations between Indian Chartered Accountant firms and international entities by establishing a formal registration framework.

They seek to enhance global opportunities, foster innovation, ensure regulatory oversight, and align practices with international standards. The guidelines define key terms, detail the registration process (including forms, fees, and timelines), designate responsibilities to a Nodal Officer, and mandate reporting of structural changes. Comments can be submitted via an online form, email, or post.

Exposure Draft: Guidelines for Overseas Network

The Committee for Aggregation of CA Firms (CACAF) of The Institute of Chartered Accountants of India (ICAI) presents a draft of proposed guidelines for “Overseas Networks.” The purpose is to gather public comments on these guidelines by June 27, 2025.

Purpose of the Guidelines

The primary goal of these guidelines is to establish a framework in India to regulate and develop professional networks within the chartered accountancy profession. Key objectives include:

1. Strengthening professional opportunities for ICAI firms both domestically and internationally.
2. Fostering innovation and competition by providing a level playing field.
3. Enabling ICAI member firms to collaborate with Overseas Networks.
4. Bringing Overseas Network operations that impact the Indian chartered accountancy profession under India’s regulatory control.
5. Improving the quality of professional services by aligning with global best practices.
6. Enhancing the capacity of domestic Chartered Accountants firms through knowledge and technology sharing.
7. Promoting the integrity and resilience of the profession.

These guidelines, once issued, will apply to both existing and newly formed Overseas Networks.

Key Definitions

Here are some important terms as defined in the guidelines:

• Act: The Chartered Accountants Act, 1949 (as amended).
• Chartered Accountant: An ICAI member as per Section 4 of the Act.
• Code of Ethics: Ethical standards issued by ICAI.
• Domestic Entity: Indian CA firms or ICAI-registered management consultancies.
• Overseas Entity: Professional service providers (like accounting or assurance) operating outside India.
• Overseas Network: A collaboration between Domestic and Overseas Entities involving:
  • Shared costs, quality control, or strategy
  • Use of common brand/logo/email/domain
  • Shared professional resources
  • Any setup implying unified operations
    (Note: Shared coworking space alone doesn’t count)
• Nodal Officer cum Contact Point: An ICAI member from the Domestic Entity responsible for compliance.
• Good Standing: An ICAI member who pays dues, completes CPE hours, and has no pending disciplinary action.

Registration of Overseas Network

All Network arrangements between Domestic and Overseas Entities must be registered with ICAI.

Application for Name Approval

1. An application for name approval must be filed by the Domestic Entity(ies) through its Nodal Officer using Form ‘AO’ along with a fee of INR 10,000/-.
2. The application must include specified documents.
3. The Overseas Network must have a distinct name approved by ICAI.
4. ICAI may reject undesirable names, and relevant Indian laws (e.g., Companies Act, Trademark, Copyright) will apply. An opportunity for hearing will be granted before rejection.
5. The approved name will be reserved for 90 days. Approval of name does not constitute registration.

Registration Process

• The Nodal Officer must apply for registration using Form ‘BO’ within 90 days of the name approval.
• The application must include prescribed documents and a fee of INR 40,000/-.
• ICAI may request additional documents, which the Nodal Officer must submit within 60 days.
• If all requirements are met, ICAI will approve the registration, allot a Unique Registration Number, and inform the Nodal Officer.
• If the application is incomplete, ICAI will reject it after recording reasons and informing the Nodal Officer. A fresh application can be submitted within 90 days of the name approval.
• Existing network arrangements must register with ICAI within 120 days of these guidelines commencing.

Nodal Officer cum Contact Point

The Nodal Officer is a key figure in the Overseas Network’s compliance.

• They must be an ICAI member in good standing.
• They can be a Managing Partner, Joint Managing Partner, Designated Partner of LLP, or a Partner with the highest profit-sharing/capital contribution.
• They can be from any Domestic Constituent registered with ICAI.
• A one-time password (OTP) will be sent to the Nodal Officer during registration and for changes in the Network’s constitution.
• The Nodal Officer is responsible for ensuring compliance with policies, procedures, record maintenance, and legal requirements.
• Violations by any constituent that benefit a Chartered Accountant firm registered with ICAI may lead to disciplinary proceedings against the Nodal Officer.

Changes in Composition of Overseas Network Post-Registration

Any changes in the Network’s composition, such as additions or departures of constituents, must be intimated by the Nodal Officer by filing Form ‘CO’ within 30 days of the change, along with a fee of INR 10,000/-.

Public Comments

Comments on this Exposure Draft are most helpful if they contain a clear rationale and specific suggestions.

Submission Methods for Comments (Latest by 27th June 2025):

For further clarifications, you can email cacaf[at]icai[dot]in.

The proposed ICAI guidelines for Overseas Networks mark a significant step toward strengthening international collaboration, transparency, and regulatory oversight in the chartered accountancy profession. By formalizing partnerships between Indian and global firms, the initiative aims to enhance professional standards, encourage innovation, and empower domestic CA firms to compete globally. Stakeholders are encouraged to review the draft and submit their feedback by June 27, 2025, to help shape a robust and future-ready framework.