Practice Unit Checklist Before Filing Form 1 — Avoid Common Rejections
A pre-flight checklist for Indian CA firms (Practice Units) about to file Form 1 for ICAI Peer Review. Cover the 10 most common rejection / clarification triggers BEFORE the PRB sees your application.
The biggest reason Peer Review applications get delayed isn't the on-site visit — it's the Form 1 filing stage. Firms file with incomplete data, miss a Cl. 17 disclosure, or misclassify engagements, and the PRB Secretariat sends back clarification queries that eat 1-2 weeks.
This pre-flight checklist catches the 10 most common issues BEFORE you click submit.
① Firm-master data matches ICAI portal
Open the ICAI Member Search portal and Firm Search portal. Cross-check that the data you're about to enter in Form 1 matches exactly:
- Firm name (spaces, punctuation, "& Co." vs "& Associates")
- FRN
- Date of constitution
- Current partner list (current MRNs)
- Branch addresses (PIN codes especially — typos here trigger re-verification)
- LLP conversion details (if applicable)
Why it matters: Mismatches automatically generate Secretariat queries. The application is held in pending status until reconciled.
② Partner roster covers the full review period
If your review period is FY 2023-24 to FY 2025-26 (3 years), Form 1 must declare every partner who was active during ANY part of those years — not just the current ones.
Include:
- Partners who retired or left during the period (with dates)
- Partners admitted during the period (with admission dates)
- Designated partners (for LLPs)
③ Concentration disclosure (Cl. 17) is explicit
If any client accounts for ≥ 15% of your assurance gross receipts in any of the review FYs, declare it. Even if no client crosses 15%, explicitly state that in the relevant field — don't leave it blank.
Why: A blank concentration field is interpreted as "missing data" not "no concentration".
④ Engagement categorisation (A-K) is complete and accurate
Form 1 Part A4 asks you to classify all assurance engagements into 11 categories (A through K). Common mistakes:
- Double-counting an engagement that fits two categories
- Putting a listed-bank audit under "A. Bank" when it should be under "D. Listed Entity" (more stringent category wins)
- Missing Internal Audits or Tax Audits that count under "K. Any other assurance services"
Tip: Build a spreadsheet of every engagement first, classify, then transcribe into Form 1.
⑤ Articled-assistant register is reconcilable
Form 1 captures the article-clerk count + roster. The PRB occasionally cross-checks against your ICAI Articled-Clerk register on file. Make sure:
- Total active clerks matches
- Joiner-leaver dates within the review period are captured
- Any disciplinary or termination is disclosed honestly
⑥ CPE compliance certificates ready
For each partner, you must report:
- Structured CPE hours (last 3 calendar years)
- Unstructured CPE hours
- Total per the ICAI requirement
Partners short on CPE should have a documented remediation plan. Pretending to meet CPE when you haven't is a flag the reviewer will spot during the on-site.
⑦ FRRB / Regulator advisories — full disclosure
Cl. 14(ii) of the Guidelines mandates disclosure of any FRRB observations received and Cl. 14(iii) covers Regulator advisories (SEBI, RBI, IRDAI, C&AG, NFRA). Even if the matter is closed, declare it.
Hiding a known advisory is a Cl. 22 revocation trigger if discovered later.
⑧ Pending disciplinary matters declared
Any pending matter under the CA Act — for the firm or any partner — must be disclosed in Form 1 Part B(II). The Disciplinary Directorate can confirm pending status directly with the PRB, so don't try to hide.
⑨ SQC 1 questionnaire fully answered
Part B(I) has 36 SQC 1 items split across 6 elements. Every item must have a Yes / No / N/A answer. Blanks read as "No".
Honest "No" beats dishonest "Yes" — the reviewer's on-site testing will catch overclaims.
If you have genuine "No" responses, add a remediation plan in the free-text comments. Reviewers appreciate transparency + a path forward.
⑩ AQMM v2.0 Part C — if listed-entity audits
If you audit ANY listed entity (excluding branch-only audits of banks/insurance cos), Part C (AQMM) is mandatory since 1 April 2023.
Complete it honestly. The reviewer will independently re-score every item and document differences in Annexure III. Overstated self-scores damage your standing.
Bonus: documents to keep ready (for upload)
Have these scanned PDFs available before starting Form 1:
1. Firm registration certificate 2. Partnership deed / LLP agreement (latest version) 3. Current partners' ICAI member cards 4. CPE certificates (last 3 yrs, per partner) 5. Articled-Clerks register summary 6. Latest 3 FYs' fee details by engagement type 7. FRRB / Regulator advisories (if any) — full copies 8. Disciplinary status confirmation (DC) — even if "Nil", get a printed Nil declaration
Use the online tool to avoid mistakes
Our Form 1 Filing Tool bakes most of these checks into the form itself:
- Pre-fills firm data from ICAI portal (where available)
- Validates partner-roster dates against review period
- Flags missing Cl. 17 disclosure with an inline warning
- Prevents engagement double-counting via category dropdown
- AQMM Part C with live scoring + level computation
- Pre-flight checklist pop-up before submission
After Form 1 — what to expect
If your Form 1 is clean:
- PRB acknowledges receipt within 2 WD
- Sends panel of 3 reviewers within 3 WD (Day 4)
- You pick one within 1 WD (Day 5)
- Reviewer files Form 2 within 2 WD (Day 7)
- The 20-day clock is now active
If your Form 1 has issues, the PRB Secretariat emails clarifications. Each clarification round adds 3-5 working days to the cycle.
Bottom line
The PRB doesn't reject Form 1 for minor issues — they ask for clarifications. But every clarification round delays your certificate, eats your reviewer's bandwidth, and creates audit-trail noise. Spend 2-3 hours on this checklist BEFORE submitting and you'll save 2-3 weeks downstream.
Need a quick review of your draft Form 1? WhatsApp CA Jatin Tagra at +91 99531 40464 — happy to flag pre-submission issues.
Try the tools, free
File Form 1, check Form 3 eligibility, or run the 20-day Peer Review tracker — all online, no install.