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ICAI Peer Review Explained: Who Needs a Certificate and What Firms Should Prepare

ICAI Peer Review is a mandate-linked review of a practice unit's audit quality. Phases, who needs a certificate, process, SQM 1 link and what to prepare.

CCORAA Team10 October 20266 min read

Peer Review is the ICAI Peer Review Board's examination of whether a practice unit's attest work and quality control meet professional standards. Under the Peer Review Mandate, holding a valid Peer Review Certificate is a prerequisite for undertaking statutory audits in categories that are being phased in, starting with audits of listed entities from 1 April 2022.

Facts checked: 10 October 2026. Phases and criteria as originally announced were read on icai.org (Peer Review Board notices of 11 April 2022 and 5 April 2022). The list and dates of later deferment notices were read on the ICAI Peer Review Mandate page (titles only; notice texts not opened). The SQM 1 deferment was read in the AASB announcement of 31 March 2026 on icai.org. Revised phase dates after 2023, the Phase IV date of 31 December 2026, and the 1 October 2022 Guidelines date are from secondary reporting. The certificate validity period and process steps could not be verified from the Guidelines text, which icai.org did not serve to our tools. Check the current notices before advising a client.

What it is

The Peer Review is carried out under the Peer Review Guidelines, which per ICAI material were prescribed under section 15(2)(fa) of the Chartered Accountants Act and applied from 1 October 2022. A reviewer, who is an ICAI member empanelled and appointed by the Peer Review Board, examines the practice unit. The outcome is the Board's decision on whether to issue or renew a Peer Review Certificate.

Who needs a certificate

The Council's mandate rolls out in four phases. A firm that already holds a valid certificate does not need a new review until it expires.

Phase Original start Who is covered (as announced)
I 1 April 2022 Practice units auditing entities with equity or debt securities listed in India or abroad, as defined in the SEBI LODR Regulations, 2015
II 1 April 2023 Unlisted public companies with paid-up capital of at least ₹500 crore, or turnover of at least ₹1,000 crore, or loans, debentures and deposits of at least ₹500 crore on 31 March of the preceding year; and attestation units with 5 or more partners
III 1 April 2024 Entities that raised more than ₹50 crore from the public, banks or financial institutions in the period under review, and bodies corporate including trusts classed as public interest entities; and attestation units with 4 or more partners
IV 1 April 2025 Audits of branches of public sector banks; and attestation units with 3 or more partners

SEBI already requires listed-entity auditors to hold a valid certificate, so Phase I is additive to that requirement.

What changed in 2022 to 2026

ICAI's notice list shows: the revised roll-out of 11 April 2022; the Phase II roll-out of 9 November 2022; deferments of Phase II on 10 May and 19 July 2023; revised applicability of Phases II and III on 16 March 2024; clarifications and FAQs on 24 December 2024; deferment of Phases III and IV on 22 January 2025; and a deferment of Phase IV on 31 December 2025. Secondary reports put the current dates at 1 July 2024 for Phase II, 1 July 2025 for Phase III and 31 December 2026 for Phase IV. Do not rely on a date without opening the notice.

A separate mandate requires firms auditing listed entities, banks other than co-operative banks, and insurance companies to evaluate their audit quality maturity (AQMM) from 1 April 2023, with the level reviewed alongside the peer review cycle.

The process in outline

  1. The firm applies to the Peer Review Board in the prescribed form.
  2. The Board assigns a reviewer.
  3. The reviewer examines the firm's quality control system, engagement files and compliance with standards.
  4. The reviewer reports, and the Board decides on the certificate.
  5. The certificate carries a validity date, and the firm must be reviewed again before it ends.

Steps and form names should be confirmed in the Guidelines; this outline is from our knowledge of the process, not from the Guidelines text.

ICAI issued SQM 1 and SQM 2 in October 2024 to replace SQC 1. The Council's decision of 30 and 31 March 2026 deferred their mandatory effective date until further announcement, so SQC 1 continues to apply. Peer reviewers test against the quality control standard in force, so firms should keep SQC 1 documented while building towards SQM 1. See the engagement quality review guide and SA 220.

What firms should prepare

Area What the reviewer expects to see
Quality manual Written policies on acceptance, independence, staffing, consultation, monitoring
Engagement files Complete working papers assembled on time, with sign-offs; see working paper inspection readiness
Review evidence Partner and, where required, EQR sign-off; see the EQR guide
Independence Annual declarations and conflict checks
Training CPE records for partners and staff
Reporting UDIN on each document; see UDIN

Worked example

A five-partner firm audits a mix of private companies and an unlisted public company with turnover of ₹1,200 crore. The turnover exceeds ₹1,000 crore, so the unlisted public company is within the Phase II description, and the firm's five attestation partners place it there too. Before accepting the next appointment, the managing partner checks the Peer Review Board's list of notices and applies. A firm that cannot show a valid certificate when the phase is operative would be unable to accept that audit under the mandate.

Frequently asked questions

Is peer review mandatory for all CA firms?

No. It applies to the categories in the phases of the mandate, including firms with a stated number of attestation partners. Other firms can undergo it voluntarily.

How long is the Peer Review Certificate valid?

The certificate carries a validity date set under the Guidelines. We could not verify the period from the Guidelines text, so check the certificate and the Guidelines.

Who conducts the review?

An ICAI member empanelled as a reviewer and appointed by the Peer Review Board.

Does SQM 1 replace peer review?

No. SQM 1 governs the firm's quality management system, and peer review checks compliance. SQM 1 is deferred, and SQC 1 remains applicable.

Is the Peer Review Certificate the same as the AQMM level?

No. They are separate mandates, but the AQMM level is reviewed with the peer review cycle for covered firms.

See also the audit glossary for quality control terms.

Topics
peer review icaiicai peer reviewpeer review certificatepeer review board icaipeer review mandate phasespeer review guidelines 2022peer review certificate for statutory auditicai peer review who needs
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