From Flexibility to Fixation: ICAI Tightens the Tax Audit Cap

Introduction

The landscape of professional audit responsibilities for Chartered Accountants is witnessing a significant shift. For years, the ICAI’s advisory guideline of 60 tax audits per CA per financial year remained a soft ceiling — honoured more in spirit than in strict enforcement. However, with rising concerns about audit quality, overburdened signatories, and imbalanced workload distribution in firms, the ICAI has now taken a bold step.

Effective from FY 2026–27, the 60-audit limit is no longer a mere recommendation but a mandatory cap per partner. The move redefines how firms allocate and manage tax audit assignments, strictly prohibits proxy signings, and aims to promote a culture of accountability and equitable participation across all levels of the profession.

Existing Guidelines

> Since 2008, ICAI recommended (but did not strictly enforce) a limit of 60 tax audits per Member per financial year (‘FY’)

> Under this setup, solo practitioners could conduct up to 60 tax audits in a FY.

> In partnership firms, the aggregate firm limit was the sum of individual partners’ limits.

 

Example:

CA Raj Mehta is a partner in a firm called RMP & Associates. The firm has 5 partners.

As per ICAI’s old guideline: –

Each partner can do up to 60 tax audits in a FY = 5*60 = 300 tax audits in a FY for the firm.

BUT in reality…

Partner 1 (CA Raj Mehta) signs 200 tax audits, other partner signs 20–30 each.

Still compliant on paper — because the firm as a whole is under 300 tax audits.

This leads to senior partner (CA Raj Mehta) signing on behalf of other partners enabling to exceed his personal cap.

New Guidelines from FY 2026–27

> The 60 audit limit in a FY become binding cap per partner, not just a recommendation.

> Proxy signing is disallowed. Each partner must personally sign tax audit reports and shall be held responsible for such audit reports.

> Audit mandated under other sections of Income Tax Act (such as special audit) are not counted towards the limit.

 

Example:

Same firm: RMP & Associates with 5 partners.

As per ICAI’s new guideline: –

CA Raj Mehta can sign only 60 tax audit report, no matter how many clients he has. Remaining tax audit report must be signed by other partners.

If the firm has 300 audits, it must be divided equally or fairly among all partners leading to Fair Workload Distribution and Equitable responsibility.

Key Differences Summary

Aspect

Old Guidelines

New Guidelines (FY 2026–27)

Nature

Advisory, not binding

Mandatory limit per partner

Applicability

Solo CAs: 60 Audit in a FY / Firm: total of all the partners

Each partner capped at 60

Proxy Signing

Allowed, common in practice

Not Allowed

Audit Counting

Solo and firm combined

Solo + firm combined per partner

Legal Force

Lack enforcement

Formal disciplinary implications

Rationale & Professional Impact

> Audit quality – Capping will ensure Partners will ensure quality time per audit.

 

> Fair Workload Distribution – Junior and mid-level partners gain much needed exposure and opportunity.  

 

> Equitable responsibility – Prevents senior partners from over-relying on firm limits.

 

> Firm structure shifts: Incentivizes firms to increase genuine partnerships and delegate.