Policy For Selection and Appointment of Statutory Central Auditors (Scas) For The Year 2022-23
Policy For Selection and Appointment of Statutory Central Auditors (Scas) For The Year 2022-23
1. Preamble:
2.2. For PSBs, empanelment of audit firms eligible for appointment as SCAs will continue to
be done by the office of C&AG, based on the norms prescribed by RBI, as on January 1
of the relevant year. The list of firms as furnished by C&AG to RBI will be subjected to
scrutiny by RBI for identifying the eligible firms and excluding audit firms who have
been denied audit by C&AG/RBI. RBI will forward a single list of all audit firms eligible
for appointment as SCAs to all PSBs on an annual basis. PSBs shall shortlist audit firms
from the said list of eligible audit firms as received from RBI, based on certain objective
criteria (like number of full-time partners, number of professional staff, number of
CISA/ISA qualified partners/paid CAs, number of FCAs, etc.) as laid down in the bank’s
policy for appointment of statutory auditors.
2.3. Further, the PSBs shall place the list of shortlisted firms, in order of preference, before
the ACB for selection of SCAs in a transparent manner. Upon selection of SCAs by the
PSBs in consultation with their ACB and verifying their compliance with the eligibility
norms prescribed by RBI, the PSBs shall seek RBI’s prior approval for appointment of
SCAs.
2.4. From FY 2021-22, as per RBI revised guidelines for selection and appointment of
Statutory Central Auditors, RBI is providing a single list of eligible audit firms to PSBs.
The firms in said list would not be ranked in any order and all firms would be eligible
for selection by all PSBs.
2.5. The RBI guideline further requires the Bank to formulate a Board Approved Policy to be
hosted on its official website/public domain and formulate necessary procedure
thereunder to be followed for appointment of SCAs. Apart from conforming to all
relevant statutory/regulatory requirements in addition to these instructions, this should
afford necessary transparency and objectivity for most key aspects of this important
assurance function.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
2.6. All Commercial Banks (excluding RRBs) and UCBs will be required to take prior approval
of RBI (Department of Supervision) for appointment/reappointment of SCAs/SAs, on an
annual basis in terms of the above-mentioned statutory provisions. For the purpose, the
Public Sector Banks (PSBs) should apply to Department of Supervision, Central Office,
RBI within one month of receipt of list of eligible audit firms from RBI.
3. Number of Audit Firms and Vacancy Position for the year 2022-23:
3.1. The Entities (Bank) can decide on the number of SCAs based on a Board Approved Policy,
inter alia, taking into account the relevant factors such as the size and spread of assets,
accounting and administrative units, complexity of transactions, level of
computerization, availability of other independent audit inputs, identified risks in
financial reporting, etc.
3.2. However, in terms of the revised Guidelines, RBI has prescribed slab-wise number of
SCAs to be appointedbased on the total Asset Size of the bank as under:
3.3. The above limits have been prescribed to ensure that the number of SCAs/SAs appointed
by the Entities are adequate, commensurate with the asset size and extent of
operations of the Entities, with a view to ensure that audits are conducted in a timely
and effective manner. This will be subject to review in future based on the experience.
Considering the above guidelines and based on the asset size, our Bank can appoint
maximum 8 no. of firms as SCAs.
3.4. Considering the Asset Size of Bank of more than ₹ 10 lakh Crore as on 31st March of the
previous year, 6 SCA Firms were taken for audit assignment after obtaining the approval
from the ACB and this Policy propose to continue with the 6 audit firms which will be
appropriate for completion of audit in time with coordination and proper allocation of
the work.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
5. Independence of Auditors:
5.1. The Audit Committee of the Board (ACB) shall monitor and assess the independence of
the auditors and conflict of interest position in terms of relevant regulatory provisions,
standards and best practices. Any concerns in this regard may be flagged by the ACB to
the Board of Directors of the Bank and concerned Senior Supervisory Manager
(SSM)/Regional Office (RO) of RBI.
5.2. In case of any concern with the Management of the Bank such as non-availability of
information/non-cooperation by the Management, which may hamper the audit process,
the SCAs shall approach the Board/ACB, under intimation to the concerned SSM/RO of
RBI.
5.3. The Concurrent Auditors of the Bank should not be considered for appointment as SCAs
of the Bank. The audit of the Bank and entity with large exposure (as defined in RBI
instructions of Large Exposure Framework) to the Bank for the same reference year
should also be explicitly factored in while assessing independence of the auditor.
5.4. The time gap between any non-audit works (services mentioned at Section 144 of
Companies Act, 2013, Internal assignments, special assignments, etc.) by the SCAs for
the Bank or any audit/non-audit works for its group entities should be at least one year,
before or after its appointment as SCAs. However, during the tenure as SCA, an audit
firm may provide such services to the Bank which may not normally result in a conflict
of interest, and the Bank may take its own decision in this regard, in consultation with
the Board/ACB.
5.5. The above restrictions detailed in para 5.3 and 5.4 shall also apply to an audit firm
under the same network of audit firms or any other audit firm having common partners.
5.6. A conflict would not normally be created in the case of the following special
assignments (indicative list):
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
6. Professional Standards of SCAs:
6.1. The SCAs shall be strictly guided by the relevant professional standards in discharge of
their audit responsibilities with highest diligence.
6.2. The ACB shall review the performance of SCAs on an annual basis. Any serious
lapses/negligence in audit responsibilities or conduct issues on part of the SCAs or any
other matter considered as relevant shall be reported to RBI within two months from
completion of the annual audit. Such reports should be sent with the
approval/recommendation of the ACB, with the full details of the audit firm.
6.3. In the event of lapses in carrying out audit assignments resulting in misstatement of
Bank’s financial statements, and any violations/lapses vis-à-vis the RBI’s
directions/guidelines regarding the role and responsibilities of the SCAs in relation to
the Bank, the SCAs would be liable to be dealt with suitably under the relevant
Statutory/Regulatory framework.
7.1. To protect the independence of the auditors/audit firms, Bank shall appoint the SCAs
for a continuous period of three years, subject to the firms satisfying the eligibility
norms each year. Further, the Bank can remove the audit firms during the above period
only with the prior approval of the concerned office of RBI (Department of Supervision),
as applicable for prior approval for appointment, as mentioned at Para 2.6 of this Policy.
7.2. An audit firm would not be eligible for reappointment in the same Bank for six years
(two tenures) after completion of full or part of one term of the audit tenure. However,
audit firms can continue to undertake Statutory Audit of other Entities / Banks.
7.3. Further, the audit firms which have already completed tenure of 1 year or 2 years with
the Bank (appointed as per the existing guidelines) may be permitted to complete the
balance tenure only, i.e., 2 years and 1 year respectively, if they fulfil the eligibility
norms on an annual basis. However, in case an audit firm has conducted audit of the
Bank for part-tenure (1 year or 2 years) and then not appointed for remainder tenure,
they also would not be eligible for reappointment with the Bank for six years from
completion of part-tenure.
7.4. One audit firm can concurrently take up Statutory Audit of a maximum of four
Commercial Banks [including not more than one PSB or one All India Financial Institution
(NABARD, SIDBI, NHB, EXIM Bank) or RBI], eight UCBs and eight NBFCs during a particular
year, subject to compliance with required eligibility criteria and other conditions for
each Entity and within overall ceiling prescribed by any other statutes or rules.
7.5. For clarity, the limits prescribed for UCBs exclude audit of other co-operative societies
by the same audit firm. For the purpose of this Policy, a group of audit firms having
common partners and/or under the same network, will be considered as one entity and
they will be considered for allotment of SCA accordingly.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
7.6. Shared/Sub-contracted audit by any other/associate audit firm under the same network
of audit firms is not permissible. The incoming audit firm shall not be eligible if such
audit firm is associated with the outgoing auditor or audit firm under the same network
of audit firms.
The audit fees for SCAs of all the Entities shall be decided in terms of the relevant
Statutory/Regulatory provisions. Public Sector Banks will continue to be guided by
relevant RBI instructions in the matter.
9.1. The proposed policy for the year 2022-23 is in line with the latest guidelines issued by
the RBI. The Policy shall be valid for the Year 2022-23.
9.2. The Executive Director (in charge of Finance & Accounts) shall be authorized to approve
the changes, if any, brought out in the regulatory guidelines. The ACB/Board shall be
apprised of the changes, if any, in due course.
A) Basic Eligibility:
Note 1: There should be at least one-year continuous association of partners with the
firm as on the date of empanelment (for PSBs) for considering them as full-time
partners. Further, for appointment as SCAs, at least two partners of the firm shall
have continuous association with the firm for at least 10 years.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
For this purpose, the full-time partner’s association with the firm would mean
exclusive association. The definition of ‘exclusive association’ will be based on the
following criteria:
Note 3: Audit Experience - Audit experience shall mean experience of the audit firm
as Statutory Central/Branch Auditor of Commercial Banks (excluding RRBs)/ AIFIs. In
case of merger and demerger of audit firms, merger effect will be given after 2 years
of merger while demerger will be affected immediately for this purpose.
Note 4: Professional Staff - Professional staff includes audit and article clerks with
knowledge of book-keeping and accountancy and who are engaged in on-site audits
but excludes typists/stenos/computer operators/ secretaries/subordinate staff, etc.
There should be at least one-year continuous association of Professional Staff with the
firm as on date of empanelment for considering them as Professional Staff for the
purpose.
B) Additional Consideration:
i) The audit firm should be duly qualified for appointment as auditor of a company
in terms of Section 141 of the Companies Act, 2013.
ii) The audit firm should not be under debarment by any Government Agency,
National Financial Reporting Authority (NFRA), the Institute of Chartered
Accountants of India (ICAI), RBI or Other Financial Regulators.
iii) The Entities shall ensure that appointment of SCAs/SAs is in line with the ICAI’s
Code of Ethics/any other such standards adopted and does not give rise to any
conflict of interest.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
iv) If any partner of a Chartered Accountant firm is a director in any Public Sector
Bank (PSB), the said firm shall not be appointed as SCA/SA of any PSB. Further, if
any partner of a Chartered Accountant firm is a director in any Entity, the said
firm shall not be appointed as SCA/SA of any of the group entities of that entity.
Explanation: For the purpose of this Policy, Group entities shall mean two or more
entities related to each other through any of the following relationships, viz.
Subsidiary – parent (defined in terms of AS 21), Joint Venture (defined in terms of
AS 27), Associate (defined in terms of AS 23), Promoter-promotee [as provided in
the SEBI (Acquisition of Shares and Takeover) Regulations, 1997] for listed
companies, a related party (defined in terms of AS 18), Common brand name, and
investment in equity shares of 20% and above.
In case any audit firm (after appointment) does not comply with any of the eligibility
norms (on account of resignation, death etc. of any of the partners, employees, action
by Government Agencies, NFRA, ICAI, RBI, other Financial Regulators, etc.), it may
promptly approach the Bank with full details. Further, the audit firm shall take all
necessary steps to become eligible within a reasonable time and in any case, the audit
firm should be complying with the above norms before commencement of Annual
Statutory Audit for Financial Year ending 31stMarch and till the completion of annual
audit.
11.1. The appointment of SCAs will be made on an annual basis, subject to their fulfilling
the eligibility norms prescribed by RBI from time to time and also subject to their
suitability.
11.2. Based on the Vacancy position, the Bank shall shortlist minimum of 2 audit firms for
every vacancy of SCAs so that even if firm at first preference is found to be
ineligible/refuses appointment, the firm at second preference can be appointed and
the process of appointment of SCAs does not get delayed. However, in case of
reappointment of SCAs by banks till completion of tenure of continuous term of 3
years, there would not be any requirement of shortlisting and sending names of
multiple audit firms to RBI while seeking approval to appointment.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
11.3. For the convenience of audit and timely completion of consolidation of Financial
Statements, it is preferred to have at least two audit firms having their Head Office
from the same place where the banks' HO/CO is located i.e. Mumbai. However, in case
of unavailability of the SCA Firm, from Mumbai with suitable criteria and experience
required as per this Policy, the Bank may choose to appoint suitable audit firms from
outside Mumbai.
11.4. In view of the presence of the Bank across the length and breadth of the country, due
weightage for geographical representation as far as possible is to be given (i.e., North,
South, West, East and Central India) to avoid un-necessary travelling and equal
distribution of work among the auditors so that the audit can be completed in a smooth
and timely manner.
11.5. Since no ranking will be given by RBI in the list of SCA firms provided to PSBs,
preference shall be given to the audit firms who have satisfactory past association
with our Bank, having experience in audit of large PSUs/listed entities, certification
like CISA/DISA and the audit firms who fulfil the eligibility criteria and also contacted
our bank for appointment as SCAs.
11.6. As suggested by Audit Committee of the Board, following criteria are desirable.
Capability of using audit software, experience in the field of conducting special audit
e.g., forensic audit, fraud investigation, cyber security/IS Audit, Valuation
examination, IRP Certification etc. As these details are not brought in the RBI list, the
same may be separately called for from the audit firms before the selection. While
giving order of preference, an overall view shall be taken based on all the above
criteria and accordingly final shortlisting will be done.
11.7. The Bank has constituted a Committee of CGMs / GMs called “SCAs & SBAs Selection
Committee” (hereafter called as ‘the Committee’) consisting of i) Chief Financial
Officer ii) Chief General Manager – Audit & Inspection iii) Chief General Manager –
SAMV and iv) General Manager – Credit Research & Policy, for short listing and selection
of the Auditors and recommending the same to the ACB / Board.
11.8. Based on the above criteria and available details of the individual audit firms, the
Committee would select number of audit firms equal to 2 times of number of vacancies
of SCAs arising during the year out of the list of eligible SCA firms provided by RBI.
11.9. The following procedure that will be followed for selection of SCAs by the Bank:
a. Empanelment of audit firms eligible for appointment as SCAs will continue to be done
by the Office of C&AG, based on the norms prescribed by RBI, as on January 1 of the
relevant year.
b. The list of firms as furnished by C&AG to RBI will be subjected to scrutiny by RBI for
identifying the eligible firms and excluding audit firms who have been denied audit by
C&AG/RBI. RBI will forward a single list of all audit firms eligible for appointment as
SCAs to all PSBs on an annual basis.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
c. RBI will provide a single list of eligible audit firms to PSBs as the requirement of
mandatory cooling of three years and allotment of vacancies in the ratio of 60:40
between ‘Experienced’ and ‘New’ audit firms has been done away with from FY 2021-
22. The firms in said list would not be ranked in any order and all firms would be
eligible for selection by all PSBs.
d. On receipt of the eligible list of SCAs from RBI and based on the vacancy position of
the Bank, the Finance & Accounts under the guidance from the Chief Financial Officer
(CFO) will start contacting the eligible audit firms from the said list who fulfill the
objective criteria (like number of full-time partners, number of professional staff,
number of CISA/ISA qualified partners/paid CAs, number of FCAs, number of years of
audit experience, etc.) as laid down in this Policy.
e. The Finance & Accounts will prepare the list of the audit firms so contacted and who
are willing to work as SCA of the bank in the order of preference. The list shall contain
number of audit firms at least 3 time of the number of vacancies arising during the
year. The preference list along with justifications thereof shall be placed before the
Committee for deliberation and shortlisting of the number of audit firms twice of the
vacancy position for recommending to the ACB.
f. While placing the preferred list of SCA firms before the Committee, the Finance &
Accounts must ensure that the proposed audit firms are fulfilling all the eligibility
criteria set out as per the RBI guidelines and also in accordance with this Policy.
g. The shortlisted SCA Firms recommended by the Committee will be placed before the
ACB with the concurrence of the same from the concerned Executive Director in
charge of Finance & accounts.
h. Before putting up the shortlisted audit firms before ACB, the Bank shall obtain a
consent letter and certificate, along with relevant information as per Form B, from
the audit firm(s) proposed to be appointed as SCAs to the effect that the audit firm(s)
complies with all the eligibility norms prescribed by RBI for the purpose. Such
certificate should be signed by the main partner/s of the audit firm proposed for
appointment of SCAs, under the seal of the said audit firm.
i. Upon approval of selection of SCAs by the ACB and after verifying their compliance
with the eligibility norms prescribed by RBI, the Bank shall seek RBI’s prior approval
for appointment of SCAs in the order of preference.
j. The Bank shall verify the compliance of audit firm(s) to the eligibility norms prescribed
by RBI for the purpose and after being satisfied of their eligibility, recommend the
names along with a certificate, in the format as per Form C, stating that the audit
firm(s) proposed to be appointed as SCA by them comply with all eligibility norms
prescribed by RBI for the purpose.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
k. While approaching the RBI for its prior approval for appointment of SCAs, Bank shall
indicate the total asset size as on March 31st of the previous year (audited figures),
forward a copy of ACB Resolution recommending names of audit firms for appointment
as SCAs in the order of preference and also furnish information as per Form B and
Form C as mentioned above, to facilitate expeditious approval of appointment/re-
appointment of the concerned audit firm.
l. As per the present regulations, the Bank should apply to Department of Supervision,
Central Office, RBI for approval of the SCAs within one month of receipt of list of
eligible audit firms from RBI.
m. Upon receipt of confirmation from the RBI, final appointment letter will be issued to
the audit firm(s). The same will also be placed before the Board of Directors for
information.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
FORM B
Eligibility Certificate from (Name and Firm Registration Number of the firm)
B. Additional Information:
The firm complies with all eligibility norms prescribed by RBI regarding appointment of
SCAs/SAs of Commercial Banks (excluding RRBs)/UCBs/NBFCs (as applicable). It is certified
that neither I nor any of our partners / members of my / their families (family will include
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
besides spouse, only children, parents, brothers, sisters or any of them who are wholly or
mainly dependent on the Chartered Accountants) or the firm / company in which I am /
they are partners / directors have been declared as wilful defaulter by any bank / financial
institution.
Note: For the purpose of this declaration, the credit facilities availed by companies where
the partner of a firm has been appointed as non-executive director in a professional
capacity having no financial interest shall not be included.
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Central Office, 239, Vidhan Bhavan Marg, Nariman Point, Mumbai – 400021.
FORM C
2. The Bank obtained eligibility certificate (copy enclosed) from (name and Firm
Registration Number of the audit firm) proposed to be appointed as Statutory Central
Auditor (SCA) for FY _____ along with relevant information (copy enclosed), in the format
as prescribed by RBI.
3. The firm has no past association/association for _____ years with the Bank as SCA/SBA.
4. The Bank has verified the said firm’s compliance with all eligibility norms prescribed by
RBI for appointment of SCAs of Commercial Banks (excluding RRBs)/UCBs.
Signature
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