From 1 April 2026, a chartered accountant in practice can accept and sign at most 60 tax audit assignments in a financial year, and in a firm the limit belongs to each partner personally. It can no longer be pooled at firm level and shared out among partners. Only audits under clauses (a) and (b) of section 44AB, and the Form 3CA audits of entities already audited under another law, count towards the 60. Audits triggered by the presumptive-income clauses (c), (d) and (e) do not. The count runs on the date you sign the tax audit report, not the date you accepted the work or generated the UDIN.
The rule comes from the Chartered Accountants (Limit on Number of Tax Audits) Guidelines, 2025, notified by the ICAI Council in the Gazette on 25 July 2025 (F. No. 1-CA(7)/234/2025). ICAI's UDIN Directorate has published the Guidelines as an annexure to its FAQs on the ceiling for UDIN generation under tax audit, which also explain how the UDIN portal keeps the count. The position below is as it stood on 24 October 2026.
The limit is now personal to each partner
The number 60 is not new. ICAI raised the earlier limit of 45 to 60 for audits from FY 2014-15, under Chapter VI of the Council General Guidelines, 2008. What has changed is who owns the number.
Under Chapter VI, a firm's limit was 60 multiplied by its partners, and the firm could spread that total in any way it liked. ICAI's FAQ on tax audit assignments under Chapter VI put it plainly. In a ten-partner firm, the partners could collectively sign 450 reports (at the old figure of 45), distributed between them in any manner. One partner could sign all of them.
That pooling is what saved a member in a 2021 disciplinary case. The Tax Audit Monitoring Cell had charged him with 392, 371 and 357 audits in three years. In the Disciplinary Committee order in the case of CA. G. Sahadev (decided 22 January 2021), the Committee counted the partners in his firm in each of those years and found the audits within the firm limit.
Under the 2025 Guidelines that argument is not available. Paragraph 7 construes the limit, for a firm, as applying to each partner, and paragraph 8 says a partner of several firms has one limit across all of them put together. Paragraph 9 adds that audits a partner signs in his individual capacity also fall in the same aggregate. Chapter VI governed until 31 March 2026, and the new Guidelines supersede it from 1 April 2026.
| Point | Chapter VI (till 31 March 2026) | 2025 Guidelines (from 1 April 2026) |
|---|---|---|
| Number | 60 per partner (from FY 2014-15) | 60 per member, per financial year |
| Firm with several partners | Pooled firm limit, divisible among partners in any manner | Each partner's own 60; no transfer between partners |
| How compliance is tracked | Checks by ICAI's Tax Audit Monitoring Cell, as in the 2021 case above | UDIN portal aggregates every applicable tax audit UDIN of the member |
Which tax audit reports count towards the 60
Paragraph 10 of the Guidelines leaves out audits that arise under clauses (c), (d) and (e) of section 44AB. Under the text of section 44AB of the Income-tax Act, 1961, those clauses catch people under presumptive schemes who claim lower profits than the scheme deems. Clause (c) covers section 44AE, 44BB and 44BBB businesses, clause (d) covers section 44ADA professionals, and clause (e) covers businesses hit by section 44AD(4). The FAQs map this exclusion to UDIN sub-categories.
| UDIN sub-category | Typical case | Counts? |
|---|---|---|
| Form 3CA, third proviso to section 44AB | Company or other entity already audited under another law | Yes |
| Form 3CB, section 44AB(a) | Business turnover above ₹1 crore (₹10 crore where cash receipts and payments are each within 5%) | Yes |
| Form 3CB, section 44AB(b) | Professional gross receipts above ₹50 lakh | Yes |
| Form 3CB (Combined), section 44AB | Audit reported under the combined sub-category | Yes |
| Form 3CB, section 44AB(c), (d) or (e) | Presumptive-scheme cases claiming lower profit | No |
Corporate and non-corporate assessees count alike; paragraph 12 says so in terms. A large share of a typical firm's 3CA work is company audits, so the corporate clients use up the limit as fast as proprietors and partnership firms do. If you need a refresher on when 3CA rather than 3CB applies, see which of Forms 3CA, 3CB and 3CD applies.
One assignment or several?
- Head office and branches of the same assessee for the same assessment year are one assignment (paragraph 12.3 and FAQ 6). Auditing one or more branches of an entity is also one assignment (paragraph 12.4).
- Several forms for the same PAN and assessment year are one assignment. You may generate separate UDINs for them without the count going up (FAQs 8 and 9).
- Different assessment years of the same client are separate assignments (paragraph 12.1 and FAQ 7). A delayed report for an earlier year signed in the same financial year as the current one uses two slots.
- Revised reports are not counted (paragraph 11 and FAQ 5), so revising a report after a client corrects its books does not cost a slot.
- Joint work counts. Paragraph 12.2 takes into account assignments accepted singly or in combination with another practising CA or firm.
- Part-time practising partners are not taken into account when reckoning a firm's tax audits (paragraph 12.5). A member holding only a part-time certificate of practice should not be signing tax audits at all. In a February 2026 Disciplinary Committee order, a member who certified 30 tax audit reports for FY 2010-11 on a part-time certificate was reprimanded and fined ₹1,50,000.
Signing date, not acceptance date, fixes the year
The Explanation to paragraph 6 says that where acceptance and signing fall in different financial years, the year of signing is the one that counts. FAQ 2 adds that the UDIN portal works on the date of signing of the tax audit report, not on the date the UDIN is generated.
So an audit accepted in February 2026 but signed on 5 April 2026 falls in FY 2026-27 and uses one of that year's 60, even though Chapter VI was still in force when you took it on. A report signed on 28 March 2027 for which the UDIN is generated on 10 April 2027 still counts in FY 2026-27. Because the UDIN has to be generated within 60 days of signing (the UDIN generation rules for practising CAs cover the window), the signing date you enter on the portal decides which year's count it hits. Enter it as it is on the report.
How the UDIN portal enforces the ceiling
FAQ 4 says the UDIN system aggregates all tax audit UDINs a member generates, whether in individual capacity or as a partner in one or more firms. The firm's registration number on the UDIN does not change whose count it goes into.
The portal also checks that the sub-category you pick matches the facts. ICAI's UDIN Directorate announcements record field-level validation for all section 44AB sub-categories from 11 February 2026. The field-level validation questions work like this:
- Clause (a) asks whether cash transactions are within 5%, and then tests turnover against ₹10 crore or ₹1 crore accordingly.
- Clause (b) tests whether gross receipts exceed ₹50 lakh.
- Clause (d) needs either receipts up to ₹50 lakh, or receipts above ₹50 lakh up to ₹75 lakh with cash receipts within 5%, along with a lower-than-deemed profit claim and income above the basic exemption limit.
- Clause (e) needs section 44AD(4) to apply and income above the basic exemption limit.
If the audit does not meet the section 44AB criteria for a sub-category, the portal will not issue a UDIN under it (FAQ 10). Where the work is not a section 44AB audit at all, FAQ 11 points you to the "Any other Audit not covered above" option under the Audit and Assurance category. Picking a non-counting sub-category to save a slot is therefore not just wrong, it is blocked. If you later move a UDIN from a non-counting sub-category to a counting one, the assignment is added to your count; the reverse move takes it out (FAQ 9).
Worked example: one partner's FY 2026-27 count
This is an illustration. Bhavna is a full-time partner in a two-partner firm and does no work in her own name. Between 1 April 2026 and the end of the September 2026 season she has signed the following reports:
| Reports signed | Number | Counted | Reason |
|---|---|---|---|
| Business audits under section 44AB(a), AY 2026-27 | 30 | 30 | Clause (a) counts |
| Company tax audits in Form 3CA, AY 2026-27 | 8 | 8 | Third proviso counts |
| One client with head office and 3 branches, AY 2026-27 | 4 reports | 1 | Same assessee and year |
| Same client, delayed report for AY 2025-26 signed in April 2026 | 1 | 1 | Different assessment year |
| Section 44AD(4) cases under section 44AB(e) | 6 | 0 | Excluded by paragraph 10 |
| Section 44ADA professionals under section 44AB(d) | 4 | 0 | Excluded by paragraph 10 |
| Revised reports for audits already signed this year | 3 | 0 | Paragraph 11 |
| Joint tax audits signed with another firm | 2 | 2 | Paragraph 12.2 |
| Audit accepted in March 2026, signed 5 April 2026 | 1 | 1 | Year of signing |
Bhavna has signed 59 documents but used only 43 of her 60. She can sign 17 more counting reports up to 31 March 2027.
Her partner Anil has signed 75 counting reports by the same date. Together the two have 110, well inside the 120 that pooling under Chapter VI would have allowed. Under the 2025 Guidelines, Anil has gone 15 over his personal limit, and Bhavna's spare capacity does not cover him. The fix had to happen before signing: the firm should have moved 15 engagements to Bhavna as signing partner, with her doing the review a signing partner must do. Leaving Anil's signature on the report while using Bhavna's UDIN is not an option, because the UDIN is generated by the member who signs the report.
Planning the season around 60 slots per partner
- Count at engagement, not at signing. Keep a register per partner of every counting assignment, with PAN, assessment year, UDIN sub-category and expected signing date. Paragraph 13 requires every member to keep a record of tax audit assignments accepted and signed in each financial year, in the form the Council prescribes.
- Classify each audit by the clause that actually triggers it. A professional with ₹60 lakh of receipts and cash within 5% may fall under clause (d) if a lower profit is claimed under section 44ADA, or under clause (b) otherwise. The portal's questions will force the right answer, so settle it at engagement.
- Allocate signing partners before the September peak. Since the audit report is due by the specified date, one month before the return due date, most counting reports are signed in a few weeks. A partner who reaches 55 by early September needs work moved then, not on the last day.
- Watch carry-overs across 31 March. Delayed reports for an earlier year signed in a new financial year count in the new year and stack on top of the current year's work for the same client.
- Keep quality records in step. Moving engagements to another partner means that partner must own the review. The firm's SQC 1 quality-control system and the files a peer reviewer will pick for testing should show who reviewed and signed each audit.
Clients and banks who receive a report can check the UDIN against the signing member; the steps to verify a CA UDIN online show what the portal reveals to them.
What happens if a member crosses 60
The Guidelines are issued by the Council. Item (1) of Part II of the Second Schedule to the Chartered Accountants Act, 1949 makes it professional misconduct to contravene "any guidelines issued by the Council". The February 2026 order linked above quotes that clause in full. That order ended in a reprimand and a fine of ₹1,50,000. The 2021 Sahadev case shows how such matters start: the Tax Audit Monitoring Cell put a year-wise count of the member's tax audits to him, and the Committee tested it against the limit.
With the UDIN portal now adding up every applicable tax audit UDIN against the member, the count is built from UDINs the member generated personally. A breach is easier to detect than it was under Chapter VI, and the old defence of a pooled firm limit no longer applies.
Audits under section 63 of the Income-tax Act, 2025
The Guidelines are written around section 44AB of the 1961 Act. For FY 2026-27 that fits: according to the Income Tax Department's FAQs on Form No. 26, Forms 3CA, 3CB and 3CD continue for audits of years relevant to assessment years up to 2026-27. Form No. 26 applies to tax years starting on or after 1 April 2026, so the first Form 26 reports will be signed in FY 2027-28.
Those audits arise under section 63 of the Income-tax Act, 2025, which keeps the same thresholds. A business is audited above ₹1 crore (₹10 crore within the 5% cash limits) and a profession above ₹50 lakh. A separate item covers presumptive cases under sections 58(2) and 61(2) that claim lower profits. Before the FY 2027-28 season, check whether ICAI has amended the Guidelines or the UDIN sub-categories to refer to section 63 and Form No. 26, and which Form 26 audits it treats as counting.
