Understanding the 20-Day ICAI Peer Review Timeline (Annexure II Explained)

The 20-working-day envelope is the spine of every ICAI Peer Review. Defined in Annexure II of the Peer Review Manual Volume I (and Cl. 9(9) of the Guidelines), it sets the rhythm from the moment the PRB receives Form 1 to the moment the Reviewer submits Form 9 — and beyond it, you're in Form 7 (extension) territory.

This post walks each day, what happens, who does what, and where firms commonly slip.

The clock starts on Day 1 = PRB receipt of Form 1

A common mistake: thinking Day 1 is when the Reviewer is notified. It's not. Day 1 is the date the PRB receives Form 1 from the PU. By the time the Reviewer is notified (Day 7), six working days have already elapsed.

Day-by-day

Day 1 — Form 1 received at PRB

Actor: PU → PRB Secretariat Action: Form 1 + supporting documents land at the Board. What happens next: Secretariat verifies completeness within ~2 WD.

Day 4 — PRB sends panel of 3 reviewers (within 3 WD)

Actor: PRB → PU Action: Names of 3 empanelled reviewers + fee notification sent to the PU. Cl. ref: Cl. 6(4) PU's job: Pick one and notify the PRB within 1 WD.

Day 5 — PU intimates choice

Actor: PU → PRB Action: PU's preferred reviewer is communicated. Cl. ref: Cl. 6(5)

Day 6-7 — Board appoints reviewer, files Form 2

Actor: Board → Reviewer → PU Action: Appointment letter issued. Reviewer files Form 2 (Acceptance + Confidentiality Declaration) within 2 WD of receiving the PU's choice intimation. Cl. ref: Cl. 6(6), 6(7), 6(8) PU's job: Forward Form 1 + supporting documents to the Reviewer.

Day 9 — Form 5 sent (Notice of Visit)

Actor: Reviewer → PU + PRB Action: Reviewer issues Form 5 with the proposed visit dates + initial sample list. Hard rule: Within 2 WD of receiving Form 1 + minimum 2 WD notice to PU. Cl. ref: Cl. 7(2), 7(6) Common mistake: Sending Form 5 with insufficient notice. The PU has the right to ask for rescheduling if notice is less than 2 WD.

Day 10 — Form 6 (if needed) + PU response

Actor: Reviewer ↔ PU Action: If Form 1 information was incomplete or unclear, Reviewer sends Form 6 asking for additional details. PU responds within 1 WD. Cl. ref: Cl. 7(3) Important: This 1-WD response window is mandatory. PU silence is treated unfavourably.

Days 11-16 — On-site review (max 6 WD)

Actor: Reviewer at PU's premises Action: Visit, perform Compliance Procedures (test the firm's SQC 1 system) + Substantive Procedures (test sampled engagement files against applicable SAs / SREs / SRSs / SAEs). Cl. ref: Cl. 7(8), 7(9), 7(11), 7(12) Hard cap: Visit must complete within 6 WD. Exceeding → Form 7.

Day 17 — Preliminary Report

Actor: Reviewer → PU Action: If the systems and procedures are NOT adequate (per Cl. 9(2)), Reviewer issues a Preliminary Report sharing observations. PU has 2 WD to respond. Cl. ref: Cl. 9(2), Appendix XII Optional: If everything is clean (Cl. 9(1)), the Reviewer can skip Preliminary and go straight to the Final Report — but this is uncommon for first-time reviews.

Day 19 — PU's written representation

Actor: PU → Reviewer Action: PU's response to the Preliminary Report. Written, on letterhead, signed by a partner. Cl. ref: Cl. 9(3) Hard rule: Within 2 WD.

Day 20 — Form 9 submitted

Actor: Reviewer → PRB Action: Final Report + 8 mandatory attachments: 1. Final Report itself (Unqualified Appendix XIII-A or Qualified Appendix XIII-B) 2. Annexure I 3. Annexure II (SQC 1 compliance — all firms) 4. Annexure III (AQMM — listed-entity audits only, since 1 Apr 2023) 5. Sample list with basis of selection 6. Preliminary Report (if issued) + PU's representation 7. PU's filled Form 1 copy 8. Reviewer's fee receipt (individual capacity) Form 9 signed by both: Reviewer + a PU partner counter-signs the cover page. Cl. ref: Cl. 9(1), 9(7)

When you can't finish in 20 WD — Form 7

Sometimes the on-site visit takes longer, or the PU needs more time for the representation, or Form 6 clarifications are slow. The fallback: Form 7 — Joint Application for Extension of Time.

Key rules:

• Filed before Day 20 elapses, NOT after
• Joint sign-off: PU + Reviewer (+ Branch Reviewer if any)
• States the reason for delay + additional working days requested + target dates
• Typically granted 10-15 additional WD
• Cl. ref: Cl. 11(1); Cl. 11(2) lets the Board condone subsequent delay if needed

Common mistake: Filing Form 7 AFTER Day 20 has passed. This complicates things — the delay is no longer protected by Form 7 and the Board has to condone it explicitly under Cl. 11(2). Always file proactively.

Working-day math — what counts

A "working day" excludes:

• Saturdays
• Sundays
• The 3 national holidays: 26 January, 15 August, 2 October
• State or regional holidays declared by the PRB / Government
• Holi, Diwali, Eid and other festival holidays as notified

Our Peer Reviewer Tool does this calculation automatically — including admin-managed holidays for Holi, Diwali, regional festivals — and shows you the working-day-aware suggested date for every milestone, with a Form 7 banner if you're trending past Day 20.

How firms commonly slip

Day	Slip	Why it happens
5	PU doesn't intimate choice within 1 WD	Partners delay because they're researching reviewers
7	Form 2 not filed within 2 WD	Reviewer is unaware of the deadline
9	Form 5 issued with < 2 WD notice	Reviewer rushes after choice intimation
10	PU misses Form 6 1-WD response	Information request landed in spam / not seen
16	On-site visit exceeds 6 WD	Sample selection too broad; no Form 7 filed
19	PU misses 2-WD representation	PU partners on travel; no escalation
20	Form 9 incomplete attachments	Annexures forgotten; resubmission needed

Bottom line

The 20-WD timeline is tight but doable for a well-prepared PU and an organised Reviewer. The key is proactive Form 7 filing if anything threatens the Day 20 deadline — never let it pass without either submitting Form 9 OR Form 7.

Use the Peer Reviewer Tool to keep every milestone on a working-day-aware suggested date, with overdue alerts and one-click jumps to the right form when action is needed.

Question on a specific day or clause? WhatsApp CA Jatin Tagra at +91 99531 40464.