The Chartered Accountants Association, Surat (CAAS), has urged the Industries Commissionerate, Gujarat, to issue a State-wide clarification permitting Chartered Accountants to include ICAI-mandated safeguard paragraphs in certificates submitted before District Industries Centres (DICs). CAAS argued that insisting on rigid one-page certificate formats without scope limitations, management responsibility clauses, basis of verification, and restrictions on use places CAs in conflict with their professional obligations under the ICAI Guidance Note on Reports or Certificates for Special Purposes (Revised 2016). The representation emphasised that departmental formats may prescribe the information required but cannot dictate professionally non-compliant methods of certification. According to CAAS, the current practice has created friction among applicants, consultants, government authorities, and professionals, besides exposing CAs to disciplinary risks. The association sought uniform State-wide instructions ensuring that subsidy applications are not rejected merely because ICAI-compliant safeguards have been incorporated into CA certificates.
Chartered Accountants Association, Surat
Ref: CAAS/Representations/2026-27/03 | Dated: 08-06-2026
To,
The Industries Commissioner,
Industries Commissionerate,
Government of Gujarat,
Block No. 1, 2nd Floor,
Udyog Bhavan, Gandhinagar – 382010.
Email: comind@gujarat.gov.in/iccord@gujarat.gov.in
Kind Attn: Shri Swaroop P, IAS
Subject: Follow up on DIC One Pager Certifications
Respected Sir,
We write this follow-up representation on behalf of the Chartered Accountants Association, Surat (CAAS), in continuation of our regarding the insistence by various District Industries Centres upon Chartered Accountants to issue one-page certificates in rigid formats, without permitting the inclusion of essential professional safeguards mandated by the Institute of Chartered Accountants of India (ICA!).
At the outset, we acknowledge that, pursuant to our representation and subsequent interaction, the issue appears to have been appreciated at least partially at the level of the General Manager, DIC, Surat, who has shown reasonable understanding of the professional constraint under which Chartered Accountants operate while issuing certificates. However, this isolated and informal acceptance does not resolve the State-wide difficulty. In most districts across Gujarat, the older practice continues unabated, and applicants are still being compelled to submit certificates in one-page departmental formats, without scope, limitation, responsibility statements, criteria, basis of verification, or ICAI-mandated safeguards. This position is neither legally sustainable nor administratively desirable.
1. The problem is not procedural inconvenience; it is professional illegality
The issue before your office is not a mere matter of formatting, spacing, drafting style, or departmental convenience. It is a matter that strikes at the very foundation of the professional responsibilities, ethical obligations, and regulatory compliance requirements applicable to Chartered Accountants while issuing certificates intended to be relied upon by Government authorities and other stakeholders.
At first glance, the difference between a one-page certificate and a detailed certificate may appear to be merely procedural. However, from a professional and legal perspective, the distinction is substantial. A certificate issued by a Chartered Accountant carries with it an implied representation that the information certified has been examined in accordance with appropriate professional standards and that the nature and extent of such examination are adequately communicated to the user of the certificate. The format and contents of the certificate therefore determine not only what is being certified, but also the extent of responsibility assumed by the Chartered Accountant and the degree of reliance that may reasonably be placed upon the certificate by the recipient.
The act of issuing a certificate by a Chartered Accountant is not a clerical exercise, a mechanical endorsement, or a mere reproduction of figures supplied by an applicant. It is an act of professional attestation governed by the standards, guidance notes, ethical requirements, quality control principles, and disciplinary framework prescribed by the Institute of Chartered Accountants of India (ICAI), a statutory body established under the Chartered Accountants Act, 1949 enacted by Parliament. Every Chartered Accountant is legally and professionally accountable to ICAI for the manner in which certificates are issued, and any deviation from prescribed professional requirements may expose the member to disciplinary proceedings, regulatory scrutiny, and allegations of professional misconduct.
It is important to appreciate that a professional certificate serves multiple purposes simultaneously. It communicates the information sought by the authority, identifies the records and documents examined, clarifies the basis on which conclusions have been drawn, defines the scope of work performed, and sets out any limitations or assumptions that may affect the interpretation of the certificate. These elements are essential because they enable the recipient to understand precisely what has been verified, what has not been verified, and the extent to which reliance may be placed upon the certification. Without such disclosures, there is a significant risk that the certificate may be misunderstood, misinterpreted, or relied upon beyond its intended purpose.
Recognising these realities, ICAI has issued detailed professional guidance governing the issuance of certificates. The Guidance Note on Reports or Certificates for Special Purposes (Revised 2016) was formulated after extensive consideration of professional risks, stakeholder expectations, legal implications, and best practices in assurance and attestation engagements. The requirements contained therein are not optional drafting preferences but are intended to ensure transparency, accountability, consistency, and protection of both the certificate user and the issuing professional.
Accordingly, the Guidance Note on Reports or Certificates for Special Purposes (Revised 2016) issued by ICAI requires a certificate to contain, inter alia:
1. identification of the subject matter;
2. applicable criteria;
3. responsibilities of management and practitioner;
4. scope of work and procedures performed;
5. limitations of use and inherent limitations;
6. basis of conclusion; and
7. appropriately worded certification or conclusion.
These elements are not decorative appendages. They are the very architecture of a professionally valid certificate. A certificate stripped of these safeguards becomes a bare declaration, and such declaration may expose the signing Chartered Accountant to proceedings for professional misconduct.
2. Departmental formats cannot override ICAI’s professional framework
We are constrained to state, with complete firmness, that no internal circular, prescribed form, departmental checklist, portal format, or instruction by any State Government office can override the professional standards framed by ICA!.
The nuances of assurance, certification, attestation, limitation of scope, reliance on management information, materiality considerations, and restriction on use constitute a specialised professional domain. These concepts are not matters of mere drafting preference; they are integral components of a professionally valid certificate. They are understood and applied by Chartered Accountants because they are trained, regulated, examined, and disciplined for this very purpose under a statutory framework. Such professional requirements cannot be reduced to a simplified or abbreviated format merely because a departmental template has historically been circulated in a single page.
A DIC office may certainly prescribe the information it requires for the administration of a scheme. It may prescribe the numerical details, supporting documents, classification heads, eligibility conditions, scheme-specific particulars, and the manner in which relevant data is to be presented. However, it cannot dictate that a Chartered Accountant shall be prohibited from adding legally and professionally necessary safeguards required by ICA!. Nor can it insist that a certificate be stripped of essential explanatory paragraphs that define the scope of work performed, the basis of verification, the extent of reliance placed on records or representations, and the limitations applicable to the certification.
It is also important to appreciate that these safeguards are not inserted for the convenience of the Chartered Accountant alone. They serve the broader public interest by ensuring that the reader of the certificate clearly understands what has been verified, the extent of assurance being provided, and the context in which the certificate should be relied upon. Removing such safeguards increases ambiguity and may inadvertently create expectations or interpretations that were never intended by the certifying professional.
To put it plainly:
The Department may ask what information it wants; it cannot tell a Chartered Accountant to issue that information in a professionally non-compliant manner.
The Department’s authority extends to specifying the information required for processing applications, but the manner in which a Chartered Accountant discharges his professional responsibilities must remain consistent with the standards, guidance, and ethical requirements prescribed by ICA!.
3. Present practice is creating avoidable friction between clients, consultants and CAs The present insistence on rigid one-page formats is creating unnecessary friction at multiple levels and is resulting in practical difficulties for all stakeholders involved in the subsidy application process:
- between clients and Chartered Accountants, because clients are often informed that their subsidy applications may be delayed, kept pending, or subjected to objections unless the CA signs the certificate exactly in the prescribed format;
- between consultants and Chartered Accountants, because consultants understandably focus on departmental “acceptability” and procedural compliance, while CAs remain bound by professional standards, ethical requirements, and regulatory obligations;
- between Chartered Accountants themselves, because some members, under commercial or practical pressure, agree to issue bare certificates in the prescribed format, while others rightly decline to do so in order to remain compliant with ICAI requirements; and
- between the profession and the Government machinery, because the Department, though unintentionally, appears to be placing professionals in a position where compliance with departmental expectations may conflict with compliance with their statutory regulator.
This is an unhealthy and entirely avoidable situation. It creates uncertainty for applicants, inconsistency in professional practice, and unnecessary administrative disputes that serve no substantive purpose.
Where a certificate is issued without scope, limitation, basis, responsibility, or reliance paragraphs, the reader may assume a level of assurance which the Chartered Accountant never intended and could not lawfully provide. The absence of such disclosures may lead stakeholders to believe that the CA has independently verified matters beyond the actual scope of engagement. Such a certificate may later be misunderstood or misused in audit, vigilance inquiries, litigation, recovery proceedings, regulatory reviews, or disciplinary proceedings. The Department, too, is then relying upon an incomplete or ambiguous document rather than a properly structured professional certificate that clearly explains the nature and extent of the work performed and the basis on which the certification has been issued.
4. There is no prejudice to DIC or Government if safeguard paragraphs are added
We ask a simple question: what prejudice is caused to the DIC, Industries Commissionerate, or the Government of Gujarat if the CA certificate contains the required safeguard paragraphs?
The numerical data demanded by the Department remains exactly the same. The eligibility conditions remain exactly the same. The subsidy computation remains exactly the same. The information sought by the Department is neither altered nor diluted in any manner. The only difference is that the Chartered Accountant is able to present the information within a professionally compliant framework and explain:
- what records were verified;
- what was not verified;
- whether the verification was based on books, invoices, bank statements, management representation, or other records;
- whether the information is literal or derived;
- for whose use the certificate is issued; and
- what limitations apply.
Such disclosures do not create any additional burden on the Department. On the contrary, they provide clarity regarding the extent of verification undertaken and the basis on which the certification has been issued. This enables the reader to properly understand the nature and scope of the certificate and prevents any unintended assumptions regarding the level of assurance provided.
Far from weakening the certificate, these paragraphs make the certificate more credible, more reliable, and more legally defensible. They enhance transparency, reduce ambiguity, and ensure that all stakeholders—including the Department, the applicant, auditors, and oversight authorities—have a clear understanding of the basis of certification. In that sense, these safeguards protect the Department as much as they protect the Chartered Accountant.
An insistence on suppressing these safeguards serves no legitimate regulatory purpose. It does not improve scrutiny, expedite verification, or strengthen compliance. Instead, it merely creates a false sense of simplicity while increasing the risk of misunderstanding, misinterpretation, and future disputes.
5. Acknowledgment at Surat level must be converted into State-wide clarification
The partial acceptance of ICAI-compliant certificate language at the Surat DIC level is certainly a welcome development and reflects a practical appreciation of the professional obligations of Chartered Accountants. However, such acceptance cannot remain dependent upon the discretion of individual officers, informal understandings, or the personal interpretation adopted at a particular district level. What may be accepted in one district today may continue to be objected to in another district tomorrow, resulting in inconsistency, uncertainty, and avoidable hardship for applicants and professionals alike.
The Industries Commissionerate is the apex administrative authority supervising DIC functioning across Gujarat and is best placed to ensure uniform implementation of policy and procedural requirements. Therefore, the issue requires a clear, unambiguous, written, State-wide circular directing all DIC offices that:
1. Chartered Accountants shall be permitted to issue certificates in formats compliant with ICAI’s Guidance Note;
2. prescribed tables or departmental data formats may be retained, but CA safeguard paragraphs shall not be objected to;
3. no application shall be rejected, delayed, objected to, or returned merely because the CA has added scope, limitation, responsibility, reliance, restriction-on-use, or ICAI-reference paragraphs;
4. where the Department requires a specific table, the CA may reproduce such table and append the necessary professional paragraphs either before, after, or by way of annexure; and
5. officers and consultants shall not insist upon deletion of professional safeguards.
Such a clarification would not alter the substantive information required by the Department, nor would it dilute any eligibility condition under the relevant schemes. It would merely ensure that the information sought by the Department is certified in a manner that remains consistent with the professional and ethical requirements governing Chartered Accountants.
A piecemeal, officer-wise, district-wise understanding will not suffice. The issue is affecting applicants and professionals across multiple districts and therefore requires a uniform administrative response. The difficulty is systemic in nature; accordingly, the clarification must also be systemic, authoritative, and applicable throughout the State.
6. ICAI ethics are framed by a national statutory regulator and cannot be diluted by State-level forms
We specifically invite your attention to the fact that ICAI is a statutory body established under the Chartered Accountants Act, 1949, enacted by Parliament, and its ethical and professional framework is not merely a private advisory manual or a set of optional recommendations. It constitutes the professional code that governs the conduct, responsibilities, and accountability of every Chartered Accountant in India and forms the basis on which members are regulated and disciplined.
The professional standards, guidance notes, ethical requirements, and technical pronouncements issued by ICAI are developed after extensive consideration of longterm repercussions, public interest concerns, international assurance and reporting practices, reliance risks, disciplinary implications, legal exposure, and the protection of all stakeholders who may rely upon professional certifications. These requirements are therefore not casual drafting preferences or stylistic choices; they are integral components of a robust professional framework designed to ensure transparency, consistency, and accountability.
An internal format of a State department, even if issued under a Government Resolution, scheme notification, administrative instruction, or operational guideline, cannot require a Chartered Accountant to omit safeguards which his national regulator requires him to include. Such an approach would effectively place a State-level administrative format in conflict with a central professional regulatory framework governing the profession across India. This is a conflict that is entirely avoidable and, in our submission, legally unsustainable and difficult to defend from a regulatory or public-interest perspective.
7. Continuing insistence may invite disciplinary consequences against members
We also place on record that CAAS is already in discussion with members of the Central Council of ICAI and will be marking this representation to the Chairperson, Ethical Standards Board of ICAI, so that the issue is formally brought within the knowledge of the body entrusted with overseeing ethical and professional standards applicable to Chartered Accountants across the country. Given the wider implications of this issue for professional practice, we believe it is important that the matter receives appropriate consideration at the institutional level.
CAAS is also in the process of collecting instances where Chartered Accountants have issued non-compliant, one-page certificates without incorporating essential safeguards, qualifications, limitations, or other disclosures required under the applicable ICAI framework. Wherever appropriate and warranted by the facts of a particular case, such instances may be forwarded to ICAI for disciplinary examination, because the issuance of such certificates has the potential to prejudice stakeholders, create misunderstandings regarding the nature and extent of assurance provided, and ultimately bring disrepute to the profession.
This is not intended as an adversarial posture against the Department, its officers, or any stakeholder involved in the implementation of Government schemes. Rather, it is a necessary protective measure aimed at preserving the dignity, legality, credibility, and long-term reliability of professional certification. Ensuring adherence to established professional standards is in the interest of all concerned, including applicants, Government authorities, and the profession itself.
8. Our demand
In view of the above, CAAS unequivocally demands your good office to:
1. issue an immediate State-wide circular to all DIC offices clarifying that !CAI-compliant certificates must be accepted;
2. instruct all DIC officers not to object to scope, limitation, responsibility, basis, reliance, and restriction-on-use paragraphs added by Chartered Accountants;
3. clarify that one-page formats are only indicative of information required and not a prohibition against professional safeguards;
4. provide that applications shall not be kept pending or rejected merely because the CA has followed ICAI’s Guidance Note;
5. initiate a consultative process with CAAS / ICAI representatives for rationalising all CA certificate formats used under subsidy schemes; and
6. issue the clarification urgently, since several subsidy applications across Gujarat are presently pending and the present uncertainty is causing unnecessary hardship to applicants and professionals.
9. CAAS is ready for dialogue, but not for dilution of professional ethics
CAAS remains ready to assist the Industries Commissionerate in drafting acceptable formats which satisfy both:
- the Department’s information requirements; and
- the Chartered Accountant’s professional obligations.
However, we must state in clear terms that professional ethics cannot be negotiated away, diluted, or compressed into departmental convenience. A certificate without its essential safeguards is not a simplified certificate — it is a defective certificate.
We trust your office will treat this matter with the urgency, seriousness, and institutional maturity it deserves.
Regards,
For Chartered Accountants Association, Surat.
President I Secretary
Enclosure: Extracts from ICAI Guidance Note on Reports or Certificates for Special Purposes (Revised 2016) to be downloaded from https://resource.cdn.icai.org/43452aasb-an-rcsp.pdf
Copy to:
1. Hon’ble Chief Minister of Gujarat,
Chief Minister’s Office, 3rd Floor, Swarnim Sankul – 1, New Sachivalay, Sector 10, Gandhinagar, Gujarat. (Email: cmog@gujarat.in)
2. Principal Secretary / Additional Chief Secretary,
Industries & Mines Department, Government of Gujarat, Block No. 5, 3rd Floor, New Sachivalaya,
Gandhinagar. (Email: secimd@gujarat.gov.in)
3. Chairperson, Ethical Standards Board, ICAI,
The Institute of Chartered Accountants of India, ICAI Bhawan, A-29, Sector 62, Noida – 110002. (Email: esb@icai.in)
4. President, The Institute of Chartered Accountants of India (ICAI),
The Institute of Chartered Accountants of India, ICAI Bhawan, Indraprastha Marg, New Delhi – 110002. (Email: president@icai.in)
