The Institute of Company Secretaries of India (ICSI) has submitted a representation to the Public Enterprises Selection Board (PESB) requesting the inclusion of Company Secretaries (Members of ICSI) as eligible candidates for Board-level and Functional Director positions in Central Public Sector Enterprises (CPSEs). ICSI highlighted that while qualifications such as Chartered Accountant, Cost Accountant, MBA, Engineering and Economics are recognized in PESB vacancy notifications, the Company Secretary qualification is generally excluded despite its statutory recognition under the Companies Act, 2013. The Institute emphasized that Company Secretaries serve as Key Managerial Personnel and possess expertise in corporate governance, regulatory compliance, strategic planning, finance, risk management, ESG, investor relations, mergers and acquisitions, and corporate restructuring. ICSI urged PESB to recognize Company Secretaries for multidisciplinary leadership roles, including Director (Finance), Director (Strategy), Director (Corporate Affairs), Director (Commercial), and similar positions, and to issue guidance ensuring equitable consideration of the CS qualification in CPSE recruitment rules and vacancy notifications.
Institute of Company Secretaries of India
CS Pawan G. Chandak
PRESIDENT
G&CL: PESB: JUN:01/2026
June 19, 2026
Smt. Mallika Srinivasan
Hon’ble Chairperson
Public Enterprises Selection Board
Department of Personnel and Training
Government of India
Respected Madam,
Subject: Representation for inclusion of Company Secretaries as an eligible qualification for Board-level and Functional Director positions in Central Public Sector Enterprises
Greetings from the Institute of Company Secretaries of India!
The Institute of Company Secretaries of India (ICSI), a statutory body established under the Company Secretaries Act, 1980 under the administrative jurisdiction of the Ministry of Corporate Affairs, Government of India, represents over 81,000 members and more than 2.5 lakh students. The Institute is committed to promoting excellence in corporate governance, regulatory compliance, ethical business practices and professional management.
At the outset, we sincerely appreciate the significant role played by the Public Enterprises Selection Board (PESB) in identifying and recommending competent leadership for Central Public Sector Enterprises (CPSEs). The transparent and merit-based selection process adopted by PESB has substantially contributed towards strengthening governance and enhancing the efficiency of public sector enterprises.
Issue:
We wish to respectfully draw your attention to the eligibility criteria prescribed in various vacancy circulars issued by PESB for Board-level positions such as Director (Finance), Director (Commercial), Director (HR), Director (Corporate Planning), Director (Business Development), Director (Administration), Director (Projects), Director (Strategy) and other equivalent functional Director positions.
It has been observed that while qualifications such as Chartered Accountant, Cost Accountant, MBA, Engineering, Economics and other professional disciplines are specifically recognised, the qualification of Company Secretary (Member of The Institute of Company Secretaries of India) is generally not included as an eligible qualification, despite the statutory recognition and multidimensional leadership role assigned to Company Secretaries under the corporate legal framework.
ICSI Submission
In view of the above, the we respectfully submits for the kind consideration of PESB to Recognise the qualification of Company Secretary (Member of ICSI) as eligible candidates for positions such as Director (Corporate Affairs), Director (Corporate Planning), Director (Commercial), Director (Business Development), Director (Administration), Director (Strategy), Director (Finance), wherever multidisciplinary professional qualifications are considered, Director (Legal & Corporate Affairs), Director (Governance), Compliance or other equivalent functional Director positions.
We also request you to kindly issue appropriate guidance to Administrative Ministries and CPSEs to ensure that, while framing Recruitment Rules and vacancy notifications, the professional qualification of Company Secretary is given equitable consideration alongside other recognised qualifications.
Justification
The Companies Act, 2013 recognises a Company Secretary as a Key Managerial Personnel under Section 2(51), and mandates the appointment of Company Secretaries in specified classes of companies under Section 203. The Act further entrusts Company Secretaries with responsibilities relating to Board governance, statutory compliance, corporate decision-making and advising the Board on governance matters.
Further, Regulation 6 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 requires every listed entity to appoint a qualified Company Secretary as the Compliance Officer responsible for ensuring compliance with securities laws, corporate governance requirements and Board procedures.
Today, Company Secretaries serve as trusted advisors to Boards and senior management in areas including:
- Corporate Governance and Board Effectiveness;
- Corporate Laws and Regulatory Compliance;
- Strategic Planning and Corporate Restructuring;
- Enterprise Risk Management;
- ESG and Sustainability Reporting;
- Investor Relations and Stakeholder Engagement;
- Corporate Finance and Capital Market Transactions;
- Mergers, Acquisitions and Business Reorganisation;
- Public Policy and Regulatory Affairs;
- Ethics, Transparency and Corporate Accountability.
The Government of India has consistently emphasised strengthening governance standards in CPSEs through professional management, transparency and accountability. Company Secretaries, by virtue of their specialised education, statutory recognition and practical experience, possess competencies that are directly relevant for leadership positions in modern public sector enterprises.
The professional competence of Company Secretaries has progressively been recognised by the Government and regulators in areas extending beyond corporate secretarial functions, including internal audit, concurrent audit, governance, risk management, finance and compliance.
With their multidisciplinary expertise in corporate laws, finance, governance, internal controls and strategic management, Company Secretaries are well-equipped to undertake Board-level responsibilities. Their inclusion in the eligibility criteria for Director-level and equivalent positions in CPSEs would strengthen institutional governance, regulatory compliance and strategic decision-making in public sector enterprises.
Several Company Secretaries presently occupy senior leadership positions in leading public and private sector organisations, heading functions such as Corporate Affairs, Legal, Finance, Strategy, Compliance, Risk Management, Investor Relations and Business Governance. Their contribution extends far beyond statutory compliance and encompasses strategic business leadership and organisational governance.
We shall be happy to provide any further information or clarification that ma y be desired in this regard.
Thanking you
Your faithfully
(CS Pawan G. Chandak)
President
The Institute of Company Secretaries of India
