CORAA University · Free tool · 2026

Peer review applicability checker 2026

Does your firm have to hold a peer review certificate, and from when? The ICAI mandate reaches firms two ways — through the audits they take and through the number of partners. Enter both and get the phase that covers you, the date it applies from, and what the certificate has to be in place for. Phase IV, for firms with three or more partners and public sector bank branch auditors, now applies from 31 December 2026.

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The firm

Does the practice unit render attestation services?

Statutory audit, tax audit, GST audit, internal audit, certification — assurance engagements of any kind

Does it accept or sign statutory audits?

Defined by the Peer Review Board as an audit mandated by law or statute — company, bank, trust and society audits; the partner-count limb bites before accepting one

Number of partners

Statutory audits the firm holds or proposes to take

An enterprise with equity or debt securities listed in India or abroad?

Phase I — mandatory since 1 April 2022

An unlisted public company with paid-up capital of ₹500 crore or more, turnover of ₹1,000 crore or more, or loans, debentures and deposits of ₹500 crore or more?

Phase II — tested as on 31 March of the immediately preceding financial year

An entity that raised over ₹50 crore from the public, banks or financial institutions during the period under review?

Phase III — peak cash credit or working capital outstanding plus term loans disbursed, all sources together

A body corporate or trust that is a public interest entity?

Phase III — banks and insurance companies are treated as public interest entities; no ₹50 crore threshold

Branches of public sector banks?

Phase IV — statutory branch audits; co-operative bank branches are not covered

Covered, and starting to prepare? Work through the peer review readiness checklist and test the firm’s quality management system with the SQM 1 gap assessment.

How the ICAI peer review mandate decides who is covered in 2026

The ICAI Council made peer review mandatory in four phases. Each phase names a kind of statutory audit, and from Phase II onwards each also names a partner count. A practice unit is covered by the earliest phase whose description it meets, and coverage is cumulative — a firm that takes a listed-company audit is in Phase I whatever its size. As set out by the Peer Review Board: Phase I, from 1 April 2022, covers practice units that propose to undertake the statutory audit of enterprises whose equity or debt securities are listed in India or abroad. Phase II, from 1 July 2024, covers statutory audit of unlisted public companies with paid-up capital of not less than ₹500 crore, or annual turnover of not less than ₹1,000 crore, or aggregate outstanding loans, debentures and deposits of not less than ₹500 crore as on 31 March of the immediately preceding financial year — or practice units rendering attestation services with 5 or more partners.

Phase III, mandatory from 1 July 2025 after a deferment announced on 22 January 2025, covers statutory audit of entities that have raised funds from the public, banks or financial institutions of over ₹50 crore during the period under review, or of any body corporate including trusts covered under public interest entities — or practice units rendering attestation services with 4 or more partners. Phase IV covers practice units that propose to undertake audits of branches of public sector banks, or practice units rendering attestation services with 3 or more partners. Phase IV was first due on 1 April 2025, was moved to 1 January 2026, and by the announcement of 31 December 2025 now applies from 31 December 2026.

The two limbs work differently. Under the client limb, the certificate is a pre-requisite for the named audit. Under the partner limb, it is a pre-requisite “before accepting any statutory audit” — so a five-partner firm needs it even for the statutory audit of a small private company. The Peer Review Board’s clarifications add the timing: a practice unit should hold a valid certificate before accepting the statutory audit and at the time of signing the audit report, and for statutory audits already accepted before the phase became mandatory, at the time of signing. A practice unit that renders no attestation services at all is outside the mandate.

Worked example — a three-partner firm in October 2026 (FY 2026-27)

A firm with three partners does statutory audits of private companies and tax audits. Its largest audit client had a peak cash credit outstanding of ₹38 crore and took fresh term loan disbursements of ₹15 crore during the year. It has no listed clients and no bank branch audits.

Inputs

Attestation servicesYes — statutory and tax audits

Partners3

Funds raised by the largest client₹38 crore + ₹15 crore = ₹53 crore

Listed, large unlisted public, or bank branch auditsNone

Output

Phase III — funds raised over ₹50 croreCovered — in force since 1 July 2025

Phase IV — 3 or more partnersCovered — from 31 December 2026

VerdictCertificate mandatory now, under Phase III

On partner count alone the firm would have until 31 December 2026. But “raised funds” is measured as the maximum outstanding on cash credit and working capital accounts plus term loans disbursed during the period, with all sources added together — and ₹53 crore is over ₹50 crore. That one client puts the firm in Phase III, which is already in force, so the certificate must be valid when that audit report is signed.

Common mistakes

Reading the partner limb as applying only to large audits

A firm inside the partner limb needs the certificate before accepting any statutory audit, not only the kinds of audit named in the phases. Size of the client does not matter.

Testing “raised funds” on year-end balances

The Peer Review Board’s clarification takes the maximum amount outstanding on cash credit, working capital and running loan accounts during the period, plus term loan amounts disbursed during the period, from all sources together. A year-end balance under ₹50 crore does not settle it.

Applying the ₹50 crore threshold to public interest entities

The second part of the Phase III client limb — any body corporate including trusts covered under public interest entities — has no threshold. Banks and insurance companies are to be treated as public interest entities.

Assuming continuing audits are outside the mandate

For a statutory audit accepted before the phase became mandatory, the firm must still hold a valid certificate at the time of signing the report.

Treating co-operative bank branch audits as Phase IV

Phase IV covers statutory branch audits of public sector banks. The Peer Review Board has clarified that statutory branch audits of co-operative banks are not covered by it.

Planning to the date and not to the lead time

The certificate has to be in hand on the date, and a review takes time to apply for, schedule, complete and clear. Phase IV has been deferred more than once; a firm that waits on a further deferment that does not come cannot accept a statutory audit after 31 December 2026.

Frequently asked questions

Is peer review mandatory for all CA firms in 2026?+

No. In 2026 it is mandatory for practice units covered by one of the four phases of the ICAI Peer Review Mandate — by the statutory audits they take or by having 3 or more partners (from 31 December 2026), 4 or more (from 1 July 2025) or 5 or more (from 1 July 2024). A practice unit that renders no attestation services is not covered.

What is the date for Phase IV of the peer review mandate in 2026?+

31 December 2026. The Peer Review Board’s announcement of 31 December 2025 extended Phase IV from 1 January 2026 to 31 December 2026.

Which CA firms will need a peer review certificate from 2027?+

Everyone already covered by Phases I to III, plus the Phase IV firms from 31 December 2026: practice units that propose to undertake audits of branches of public sector banks, and practice units rendering attestation services with 3 or more partners. For the latter, a peer review certificate is a pre-requisite before accepting any statutory audit.

Which firms are covered under Phase III of peer review?+

Firms auditing entities that raised over ₹50 crore or public interest entities, and firms with 4 or more partners. In full: practice units that propose to undertake the statutory audit of entities that have raised funds from the public, banks or financial institutions of over ₹50 crore during the period under review, or of any body corporate including trusts covered under public interest entities; and practice units rendering attestation services with 4 or more partners. Phase III is mandatory from 1 July 2025.

Does a sole proprietor need a peer review certificate in 2026?+

Only through the audits taken — a listed entity, a large unlisted public company within the Phase II thresholds, an entity that raised over ₹50 crore, a public interest entity, or, from 31 December 2026, a public sector bank branch. The partner-count limb does not reach a proprietor.

Is a peer review certificate needed for bank branch audits for FY 2026-27?+

From 31 December 2026, yes, for statutory branch audits of public sector banks under Phase IV. Statutory branch audits of co-operative banks are not covered by that limb.

Does tax audit trigger the peer review mandate?+

It makes the firm an attestation practice, but whether it is itself a trigger is not settled in the Board’s wording. Tax audit is listed as an assurance engagement, so a firm doing tax audits renders attestation services. The partner-count limb then bites “before accepting any statutory audit”, and the Peer Review Board defines statutory audit simply as an audit mandated by law or statute, while listing tax audit separately from statutory audit among assurance engagements. A firm with 3 or more partners that does only tax audits should take the cautious reading or ask the Board.

When must the certificate be valid — on acceptance or on signing?+

Both. The Peer Review Board has clarified that a practice unit should hold a valid certificate before accepting the statutory audit and at the time of signing the audit report. For audits accepted before the phase became mandatory, it must be valid at the time of signing.

On what date is the number of partners counted?+

As on the date of mandatory applicability of the particular phase and onwards. A firm that reaches the partner count after that date is covered from when it does.

Can a newly established firm apply for peer review?+

Yes. A practice unit established for less than 12 months before the application can apply as a “New unit” under the Peer Review Guidelines, 2022 and must satisfy the additional conditions prescribed for new units.

Authoritative sources

ICAI

ICAI Peer Review Board — Deferment of Phase IV of Peer Review Mandate (31 December 2025) — Extends Phase IV from 1 January 2026 to 31 December 2026 and restates the category of practice units it covers.

ICAI

ICAI Peer Review Board — Clarifications/FAQs on the Peer Review Mandate (24 December 2024) — The four-phase table with the category wording, and the clarifications on timing of the certificate, the meaning of “raised funds”, public interest entities, bank branch audits, attestation services and partner count.

ICAI

ICAI — Peer Review Mandate announcements — The running list of roll-out and deferment announcements, including the 22 January 2025 deferment of Phases III and IV. Check here for anything issued after this page was reviewed.

ICAI

ICAI — Peer Review Guidelines, 2022 — Definitions of practice unit, assurance engagement and new unit, and the review process itself.

Always confirm against the latest version of the source. Regulations evolve and amendments are common.

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Last reviewed: 2026-10-01 · For informational purposes only — not professional advice.