CAs Can Generate Up to 10 UDINs at Once: ICAI

The Institute of Chartered Accountants of India (ICAI) has extended the Bulk Unique Document Identification Number (UDIN) Generation facility to documents falling under the “Tax Audit” and “Audit & Assurance Functions” categories.

The facility, which was earlier available only for certificates, will allow practising chartered accountants to generate multiple UDINs in a single transaction instead of entering and submitting each document separately. ICAI has also issued a set of frequently asked questions explaining the scope and procedure of the expanded facility.

According to the official ICAI FAQs on Bulk UDIN Generation, a member can generate a minimum of three and a maximum of 10 UDINs in one go under either of the newly covered categories.

Facility Expanded Beyond Certificates

Until this expansion, the bulk-generation option was confined to documents classified as certificates. Chartered accountants handling several tax audit reports or audit and assurance assignments were generally required to complete the UDIN-generation process individually for each assignment.

The extension is expected to reduce repetitive procedural work, particularly during peak compliance periods when CAs may have to generate UDINs for several audit reports within a short period.

The change, however, relates to the manner in which UDINs are generated. It does not dilute the requirement to furnish accurate and assignment-specific information for every report or document.

Each UDIN continues to be linked to a particular assignment, document and signing member. Accordingly, the particulars entered for every item in a bulk request must independently correspond with the underlying report.

No Excel File Required for New Categories

ICAI has clarified that bulk UDIN generation for Tax Audit and Audit & Assurance Functions will operate through the user interface of the UDIN Portal.

Unlike the existing bulk-generation mechanism for certificates, members are not required to prepare or upload an Excel file for the newly included categories. Instead, the details of individual reports or forms have to be added directly through the portal.

The member must follow substantially the same data-entry process that applies when an individual UDIN is generated under the relevant category. The principal difference is that multiple entries can now be collected and submitted together.

How CAs Can Use the Bulk UDIN Facility

A member intending to use the facility must first log in to the ICAI UDIN Portal and select the “Bulk UDIN” option appearing on the menu bar.

The appropriate Firm Registration Number, or FRN, must then be selected. The member must choose either “Tax Audit” or “Audit & Assurance Functions,” depending upon the nature of the documents for which the UDINs are required.

After selecting the category, the member can use the “Add Row” option to enter another report or document. The particulars required for individual UDIN generation under the selected category must be completed for every row added to the bulk request.

Once the required information has been entered, the member may either select “Save Draft” to retain the details for later completion or choose “Send OTP” to proceed with final submission. After OTP verification and submission, separate UDINs will be generated for the respective documents.

Entries Can Be Edited or Deleted Before Submission

ICAI has provided flexibility to members to review the information entered in a bulk request before it is finally submitted.

The forms or documents added for bulk generation are displayed as a list on the portal. A member can modify the information entered for a particular document or remove the entry altogether before final submission.

This review facility is important because the documents included in a bulk request may relate to different clients, financial periods, statutory provisions or types of audits. Members should therefore carefully verify every row before requesting an OTP and submitting the details.

One UDIN Per Assignment Rule Continues

The introduction of bulk generation does not mean that one common UDIN can be used for several independent assignments. The facility merely allows several distinct UDINs to be requested through a single workflow.

ICAI’s general UDIN guidance provides that a UDIN is to be generated per assignment, per signatory, at the time the document is signed. Therefore, separate assignments will ordinarily require separate UDINs even if they are entered together through the bulk facility.

For a tax audit under Section 44AB, however, ICAI has clarified that one UDIN may be used for the connected audit forms forming part of the same assignment—such as Forms 3CA and 3CD or Forms 3CB and 3CD. Separate UDINs are not required for annexures that form part of the same report.

Conversely, a statutory audit of financial statements and a tax audit are treated as separate assignments and require separate UDINs. ICAI explains that a statutory audit expresses a “true and fair” view on financial statements, while a tax audit reports whether the prescribed particulars are “true and correct.” These distinct reporting responsibilities require separate UDINs. These principles are detailed in ICAI’s comprehensive UDIN FAQs.

Key Information Required for Tax Audit UDINs

For Tax Audit documents, the member must select the appropriate statutory provision or form and provide the prescribed financial and identifying particulars.

The precise fields depend on the kind of tax audit report involved. For reports under Section 44AB, the portal may require relevant figures and information from the report, along with the assessment year, financial year and a document description.

ICAI has clarified that mandatory financial fields in the Tax Audit category accept numeric values. Optional fields may accept alphanumeric information, while additional fields may be inserted through the “Add More” option.

Members must ensure that figures entered on the UDIN Portal match the corresponding figures appearing in the signed audit report. Bulk processing should not result in figures from one client or assignment being inadvertently entered against another.

Requirements for Audit & Assurance Functions

For documents covered under Audit & Assurance Functions, the member must select the relevant type of audit and the Act, law, statute or regulation under which the assignment has been performed.

Where the precise assignment is not available in the dropdown menu, ICAI permits the member to select the option covering other audits and provide the relevant details in the document description. A similar option is available where the governing Act or regulation is not included in the portal’s list.

Depending on the nature of the assignment, key fields may include the financial year or audit period, shareholders’ or owners’ funds, gross turnover or gross receipts, cash and cash equivalents, the net block of property and equipment, and major audit observations with their financial implications.

The ICAI guidance states that figures entered in these fields should ordinarily relate to the closing date of the financial year, the engagement period or the applicable reporting date.

UDIN Remains Mandatory for Digital Reports

ICAI has reiterated in its general guidance that the UDIN requirement applies even where a tax audit report or an audit and assurance document is filed online using a digital signature.

Where an online report does not contain a designated field for quoting the UDIN, the member must still generate the UDIN and communicate it to the management or those charged with governance, as applicable, so that it can be provided to relevant stakeholders.

For tax audit reports and CA certification forms uploaded on the Income Tax e-filing portal, the UDIN is subject to portal-level validation. ICAI’s FAQs state that where a form is initially uploaded without a UDIN, the number must be generated and updated within the prescribed period to prevent the uploaded form from being treated as invalid.

What Is a UDIN?

UDIN is a system-generated identification number attached to certificates, reports and other prescribed documents signed or certified by a practising chartered accountant.

The system was introduced to help establish the authenticity of documents attributed to CAs and to prevent the misuse of their names, signatures or membership details. It also enables regulators, banks, clients and other stakeholders to verify whether a document has actually been issued by the member whose particulars appear on it.

Although bulk generation makes the administrative process faster, responsibility for the accuracy and authenticity of every document remains with the signing member.

What Chartered Accountants Should Remember

The principal features of the expanded facility are:

It covers Tax Audit and Audit & Assurance Functions.
A minimum of three and a maximum of 10 UDINs can be generated in one submission.
The process is completed directly through the UDIN Portal’s user interface.
No Excel file needs to be uploaded for these two categories.
Members may save the entries as a draft before submission.
Individual entries can be edited or deleted before the final request is submitted.
OTP verification is required for final generation.
Every report must still carry its own valid, assignment-specific UDIN unless ICAI’s rules permit the same UDIN to be used for interconnected forms forming part of one assignment.

The expansion represents an important operational improvement for CA firms managing large volumes of tax audit and assurance work. It should substantially reduce repeated navigation and authentication steps while preserving document-wise identification and accountability under the UDIN framework.

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