India’s apex accounting regulator, the Institute of Chartered Accountants of India (ICAI), has come under fire from top global professional services firms for its proposed Draft Guidelines for Overseas Networks, unveiled earlier this month. These guidelines aim to regulate the engagement of global multi-disciplinary advisory networks operating in India. However, global firms say the rules are excessively burdensome, vague, and risk stifling India’s growing professional services ecosystem.
More than 170 global accounting and advisory networks, including the Big Four—EY, Deloitte, PwC, and KPMG—operate in India. Executives say the ICAI’s proposal, while aimed at creating a level playing field, could backfire by making India an unviable destination for global networks.
“Unfortunately, it continues to attempt to kill too many birds… I fear the one that will die is the Indian Big4 dream,” said Vishesh Chandiok, CEO of Grant Thornton Bharat, expressing disappointment with the over-regulatory approach.
Concerns Over Disclosure Norms and Regulatory Overreach
Among the most pressing concerns raised by global firms is Form BO, which mandates disclosure of all civil, criminal, and disciplinary cases involving any Indian partner or employee over the past five years. Critics argue that such disclosures have little relevance to network functioning and intrude into personal domains unrelated to professional competence.
The proposed Form DO further mandates the disclosure of constituent-wise turnover, including that of global affiliates—a move seen as both impractical and intrusive.
FCRF x CERT-In Roll Out National Cyber Crisis Management Course to Prepare India’s Digital Defenders
“The term ‘constituents’ is undefined,” noted a senior Big Four partner. “If taken literally, it could include all affiliated firms globally, even if they have no link to India. This is an unworkable requirement.”
Another flashpoint is the requirement for Indian entities to report financial exchanges with global partners over three years, potentially clashing with confidentiality laws in home jurisdictions like the US or UK.
“The guidelines appear to overreach by seeking control over overseas entities,” said the CEO of a prominent Indian firm tied to a US network. “This isn’t regulation. It’s strangulation.”
Risks to Mid-Sized Firms and India’s Big Four Ambition
Industry experts argue that these guidelines could disproportionately hurt mid-sized Indian firms, many of whom rely on global networks to enhance their capabilities and meet growing demand for cross-border audits, consulting, and compliance services. The rules, if implemented in their current form, may deter new network affiliations, thus harming competitiveness.
Adding to the concern is the requirement to appoint a nodal officer responsible for global compliance—seen as an unrealistic burden that no individual can fulfill.
“Such requirements ignore how global networks actually work. These are legally independent firms operating under brand-sharing and quality control protocols,” said another senior partner. “Demanding granular data from overseas partners is overkill.”
While the guidelines appear to target greater transparency, critics argue they risk disrupting the multi-disciplinary firm model that allows firms to offer audit, advisory, and IT services under one umbrella—an increasingly essential structure in modern finance.
Algoritha: The Most Trusted Name in BFSI Investigations and DFIR Services
Calls for Rethinking and Realignment
Stakeholders are urging ICAI to reconsider its approach before finalizing the guidelines. The Committee for Aggregation of CA Firms (CACAF) has invited comments until June 27. Many hope this opens the door to stakeholder dialogue that balances regulatory oversight with operational flexibility.
Nikhil Singhi, Managing Partner of Singhi & Co, emphasized the need for a forward-looking approach that prioritizes audit quality, ethics, and independence over excessive procedural compliance. “The focus should be on ensuring high standards, not administrative overload,” he said.
As the Prime Minister’s Office pursues its vision of building India’s own homegrown Big Four, these guidelines may end up achieving the opposite by weakening the very networks that help local firms scale globally.
“Instead of enablement, these rules threaten to isolate Indian firms,” concluded an unnamed CEO. “No other jurisdiction imposes such restrictions. The intent is unclear—and the consequences could be long-lasting.”