The Institute of Chartered Accountants of India (ICAI) has issued guidelines prohibiting practising chartered accountants from responding to tenders for professional services exclusively reserved for them under a statute unless the tender document prescribes a minimum fee.
Dated October 12, 2026, the guidelines take effect immediately. They also prohibit quoting below the minimum fee specified in an eligible tender and require practising members to maintain a cost sheet for every tender response.
The ICAI Council issued the guidelines in exercise of its powers under Section 15(2)(fa) of the Chartered Accountants Act, 1949. The document is signed by ICAI Secretary CA. (Dr.) Jai Kumar Batra.
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Minimum Fee Mandatory for Statutorily Reserved Services
The principal restriction applies to tenders seeking professional services exclusively reserved for chartered accountants under any statute. A practising member cannot respond to such a tender if it does not prescribe a minimum fee, irrespective of the name given to the tender document.
Where the tender specifies a minimum fee for the assignment, members may participate. However, the fee quoted must not fall below the amount prescribed in the tender document.
The guidelines give “minimum fee” a broad meaning. The expression includes an estimated fee, professional fee or average fee, regardless of the terminology used. Accordingly, members must examine the substance of the fee provision in the tender document when assessing whether they may respond.
The document does not prescribe a common rupee amount as a minimum fee. Instead, the participation restriction is linked to the fee specified in the relevant tender.
Extremely Low Fees Prohibited Across Tendered Services
A separate requirement applies to all tender responses, including those concerning services that are not exclusively reserved for chartered accountants.
The guidelines state that the quoted fee should not be extremely low and must be commensurate with the size, value and volume of the assignment, the manpower required and the nature of the work.
This means that permission to participate in a tender does not, by itself, permit a member to quote an inadequately supported fee. Members must assess the resources and work involved before determining their bid.
The document does not set a numerical threshold for what constitutes an “extremely low” fee. Its stated criteria focus on the characteristics and requirements of the assignment.
Cost Sheet Required for Every Tender Response
Practising members must maintain a cost sheet in every case in which they respond to a tender document.
The cost sheet must incorporate details of the estimated costs of undertaking the assignment, taking into account matters such as the number of persons involved and the hours expected to be spent.
ICAI may call for these documents from a member in relation to any bid submitted in response to a tender. The requirement therefore makes the basis of the quoted fee capable of being examined by the Institute.
For members and firms, the provision makes contemporaneous documentation of staffing, time and estimated costs an essential part of tender participation.
Different Rule for Services Not Exclusively Reserved for CAs
The guidelines expressly permit practising members to respond to tenders for services that are not exclusively reserved for chartered accountants under any statute, whether or not the tender prescribes a minimum fee.
Members may also participate in such tenders irrespective of whether only chartered accountants have been invited to respond.
The distinction consequently turns on whether a statute exclusively reserves the service for chartered accountants. A tender being addressed only to CAs does not, by itself, bring the assignment within the restriction applicable to statutorily reserved services.
Nevertheless, the requirements concerning excessively low fees and maintenance of a cost sheet continue to apply to these tender responses.
Reverse Bidding Below Minimum Fee Not Permitted
The guidelines specifically prohibit responding to a reverse bidding option below the minimum fee.
Where a tendering organisation provides a mechanism for progressively reducing bids, practising members cannot use that mechanism to quote below the prescribed minimum. The restriction therefore applies to subsequent reductions through reverse bidding as well as to the fee initially quoted.
Individual Letters Seeking Quotations Excluded
The guidelines do not apply where quotations are sought from practising members or firms through individual letters.
This exclusion is expressly tied to the manner in which the quotations are invited. The document separately directs that the new guidelines be read in conjunction with ICAI’s earlier Guideline No. 1-CA(7)/03/2016, dated April 7, 2016.
With immediate implementation, practising members responding to tenders will need to identify whether the assignment is statutorily reserved, examine the tender’s fee provisions and maintain a documented estimate of the costs underlying their bid.
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