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India’s Quest to Create a Big 4 Competitor: Challenges and Opportunities

The Indian government’s aspiration to develop a homegrown audit firm that could rival the Big 4—Deloitte, EY, KPMG, and PwC—has recently gained momentum. Finance Minister Nirmala Sitharaman’s recent call for the Institute of Chartered Accountants of India (ICAI) to spearhead the creation of such a firm has reignited discussions within the auditing industry. Despite this ambition, there is significant skepticism among industry professionals, particularly within the Big 4 and mid-sized Indian firms, regarding the feasibility of this goal.

The Challenges in Building a Large-Scale Audit Firm

Creating a Big 4-like firm in India solely based on audit services presents considerable challenges. Indian Chartered Accountant (CA) firms face strict regulations that restrict their growth. Currently, these firms are prohibited from investing in other firms or receiving external investments, which limits their ability to scale. A senior partner at a Big 4 firm highlighted that the current measures taken by ICAI, such as forming committees and issuing revised networking guidelines, are insufficient to address the core issues that hinder the growth of domestic firms.

ICAI has established a committee to review existing guidelines, including those related to mergers and acquisitions (M&As) and advertising. The current code of ethics for CA firms does not allow them to advertise their services or solicit business from potential clients, which stifles growth and visibility. Despite the introduction of revised networking guidelines in 2021, the response from CA firms has been underwhelming, with fewer than 200 firms registering with ICAI. This lukewarm response suggests that the guidelines have not effectively addressed the challenges faced by smaller firms seeking to grow.

The Importance of Scale in the Audit Profession

In the audit profession, scale plays a critical role. The Big 4 firms have a significant advantage due to their size, which grants them access to extensive resources, international networks, advanced technology, and a wealth of experience. These factors create a formidable challenge for homegrown CA firms in India, which often lack the resources to compete on a global level.

The president of ICAI, Ranjeet Kumar Agarwal, noted in March that of the approximately 100,000 Indian CA firms, around 75,000 are proprietorships, and only 25,000 are partnerships. Furthermore, only about 400 domestic firms have 10 or more partners. This lack of scale hinders the ability of Indian firms to take on large, complex clients that require extensive resources and international reach.

Regulatory Hurdles and International Affiliations

Audit Firm

Current regulations are a significant barrier to the growth of domestic audit firms. Over 100 Indian audit firms have international affiliations, but they are unable to fully leverage these partnerships due to restrictions under the CA Act of 1949. These regulations prohibit firms from soliciting work or engaging in branding activities that could help them grow their business. A partner at a Big 4 firm pointed out that ICAI’s stringent regulations seem designed to keep domestic firms small and mid-sized. Additionally, the lack of investment in technology has left many Indian firms behind in critical areas like documentation, which is a crucial aspect of audit quality.

Lobbying by Big 4 firms has also played a role in maintaining the status quo. When the Reserve Bank of India (RBI) mandated joint audits for banks and non-banking financial companies (NBFCs) above a certain threshold, it resulted in a shift of business from larger firms to smaller ones. However, there was significant pushback from powerful industry sections against this norm, which illustrates the challenges faced by smaller firms in gaining a foothold in the market.

Competition Among Non-Big 4 Firms

The competition among non-Big 4 firms is intense, which further complicates the growth prospects for domestic firms. Among listed companies, there is a clear preference for Big 4 firms, leaving over 100,000 smaller firms to compete for the remaining audit business. This fierce competition makes it difficult for any single firm to gain significant size and presence in the market.

Proposed Changes to the LLP Act and Companies Act

In a bid to support the growth of domestic audit firms, the Indian government is considering changes to the Limited Liability Partnership (LLP) Act and the Companies Act. These proposed amendments aim to facilitate mergers and acquisitions among CA firms, allowing them to achieve the scale necessary to compete with the Big 4. The government believes that these changes will enable the creation of large, domestic audit firms that can handle major clients and participate in global markets.

As part of this initiative, the Ministry of Corporate Affairs (MCA) is expected to outline the details of these changes in the government’s 100-day agenda. The amendments to the LLP Act and Companies Act could be introduced during the winter session of parliament in December 2024. In parallel, the ICAI has engaged in discussions with the Ministry and is considering relaxing key provisions in its regulatory framework to support the aggregation of CA firms. This relaxation would give firms more time and flexibility to explore partnerships and enhance their capabilities.

The Road Ahead for India’s Auditing Industry

While the government’s ambition to create a Big 4-like audit firm in India is laudable, the path to achieving this goal is fraught with challenges. The restrictive regulatory environment, intense competition, and lack of scale among domestic firms are significant obstacles that must be overcome. However, the proposed changes to the LLP Act and Companies Act, along with ICAI’s efforts to relax certain regulations, could pave the way for the growth of large, competitive audit firms in India.

The success of this initiative will depend on the ability of domestic firms to adapt to new opportunities, invest in technology, and leverage international partnerships. If these firms can overcome the challenges they face, India could very well see the rise of a homegrown audit firm that can stand shoulder to shoulder with the Big 4 on the global stage.

Courtesy: Financial Express & Economic Times

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About Naresh Malhotra

Naresh is a Certified Associate of the Indian Institute of Bankers. He has completed a Diploma in Commodity Markets, a certified course in Trade Finance, and MSc. (Physics). He has 35+ years of experience in the Banking and Financial sector and 4+ years of global exposure. Specialized skills in Corporate/Mid-corporate/SME credit including stressed asset management, international banking, trade finance, strategy formulation and implementation, audit, and risk mitigation. He has worked with India Debt Resolution Company Ltd, M/s JCR & Co, Chartered Accountants, State Bank of India, etc. He regularly contributes to Business and Economy in print and visual media.

About Ramakrishnan Venkatraman

Ramakrishnan is a Certified Associate of the Indian Institute of Bankers and has completed M. Com. Ramakrishnan has over 3 decades of Qualitative Banking experience in diverse areas of Banking and Banking oriented IT Solutions including Delivery Management with Customer Operations and IT Project Management including vendor management. He is a senior advisor with exposure to all aspects of the Bank’s systems, procedures, manual of instructions, regulatory requirements, Anti-money laundering policies, Business process reengineering, and establishment of controls for mitigating risks. He worked as a General Manager and Head of Core Banking Solutions for a Technology Company and as a Vice President looking after processes and special projects for a private-sector bank and with Andhra Bank.

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Shailesh Gandhi is a retired professor from IIMA with an overall experience of 30+ years in the finance & accounting domain.  He is a Chemical Engineer and is a Fellow IIMA. He specializes in various fields such as Financial reporting & analysis, management control, and  performance measurement and management systems. Shailesh is also a Independent director and a member of the audit committee on the board of Gujarat Mineral Development Corporation (GMDC), a member on the board of IIM, Nagpur and the chairperson of the audit committee as well as a member of the finance Committee, Indian Institute of Public Health, Gandhinagar. In the past, he was also a member of the Cost Accounting Standards Board of the Institute of Cost & Management Accountants of India (ICMA).

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He has conducted trainings to build capacity of teams and stakeholders. In his tenure across various organizations in corporate, consulting and development sectors, he has built capacities of staff, stakeholders, decision makers, influencers, service providers in the areas of innovative thinking and ideation; business orientation, management and continuity; business planning and operations; supply chain management; product pricing and packaging; marketing and sales management; financial management. The objectives of these sessions were to instil logical, rationale, systemic and futuristic thinking; process orientation; business/project cycle and flow.

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Dr Ravikant has 40 years of experience in Capacity Building, Urban Finance & Management, Administrative and  Taxation reforms. He has worked for almost all multilateral organisations including the World Bank, ADB, UN Habitat, USAID, DFID etc. as a consultant in India and outside India. He has worked for Government of India, Various State Governments and Municipal Governments in India and leading National and International Consulting firms in India and abroad. He has successfully implemented the conceptualization, designing & implementation for innovative Municipal Financial, Budgetary, Resource Mobilisation and Accounting System Reforms and their computerization in Vadodara Municipal Corporation. He has worked as a Team Leader of Technical Support Unit (funded by Bill and Melinda Gates Foundation) for National Urban Livelihood Mission (NULM) in Ministry of Housing and Urban Affairs, GoI – Delhi and has acquired expertise in areas like social mobilisation and institutional building, skilling, financial inclusion, and livelihoods of the urban poor. He has worked as an Urban Adviser to Urban Management Centre – Ahmedabad. He has written several books and articles regarding various urban issues / problems in regional language to create public awareness and more than 33 research papers in different seminars and workshops many of them have got published in different journals.

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About S Narendran

Narendran has more than 25 years of experience in formulating and implementing strategic and tactical plans. He is especially proficient in executing global transformation programs for cost optimization and customer experience with exposure to a wide variety of tools. He also has deep expertise in formulating effective processes and managing modern business systems in challenging and diverse environments and change management. He has worked on projects in important sectors like Aerospace, Defence, Auto, Chemicals, Construction, FMCG, Logistics, etc. He has extensive management consulting experience at organizations like Renoir Management Consulting, Go Airlines, Tech Mahindra, and Siemens. He has done an executive program in management from Columbia Business School and his Post Graduate diploma in Business Management.  He has credentials of being one of the first person in India to lead an automation project (IoT) for a discrete manufacturing firm in India. He has presented papers on improving productivity by changing human behaviour in international conferences and has also conducted workshops on Change Management in IIM-Calcutta.

About Shreyamun Mehta

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About Drumil Patel

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Aarti Saxena is BA, MA (Economics) & M.Sc (Social Policy & Planning in Developing Countries). She has over 12 years of collective and diverse experience in infrastructure development consulting, research and entrepreneurship. She has development consulting experience in business plan preparation, strategy & roadmap development, industry & market analysis, benchmarking, project management, operations management, client relationship & people management. She has vast experience in multi-cultural environments & with various tiers of government, private sector, and donor agencies. Sector exposure includes industrial clusters, SEZs, real estate, tourism, maritime, social development, and urban infrastructure. She has earlier worked with Ernst & Young LLP, Crisil Risk & Infrastructure Solutions Limited, Sai Maritime Group and Tomkins Research Ltd.

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Sanjay Rego is a practising Lawyer and a qualified Chartered Accountant. He is a member of the Society of Trust and Estate Professionals, STEP) and also holds a Post Graduate Diploma in Securities Laws. Sanjay has over 24 years of post-qualification experience of which about 14 years with Deloitte and has advised clients on matters relating to personal, trust commercial, tax, FEMA and corporate laws and relating to shareholder agreements. He specialises in estate planning and advises HNI’s with regard to their estate and succession plans. This includes drafting of Wills, Trust structures, advising of family agreements, Family Constitutions etc. He assists in advising clients on complex issues and has been able to provide innovative solutions to problems considering legal (including personal and inheritance laws), tax, and financial implications. Sanjay headed the legal, finance, and operations functions for about 5 years with Universal Trustees.

About Prakash Iyer

Prakash Iyer is an MBA, CFA and B.Sc (chemistry). Earlier an Associate Director with Meghraj Capital Advisors Pvt Ltd, Head-PPP with CRISIL Infrastructure Advisory, Sr. Associate Vice-President with Darashaw & Company Pvt Ltd and has also worked with Fortress Financial Services Ltd. He has 18 years of consulting experience in infrastructure development and has actively worked on promoting the development of infrastructure projects across sectors such as urban transport, urban regeneration, smart cities, land development, water supply and sanitation, roads, power, oil and gas, sports infrastructure, industrial parks, education parks and logistics with a special emphasis on projects being developed through PPP. He has worked with lenders, investors, multilateral agencies, government entities as well as private sector entities.

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