Summary: The Institute of Company Secretaries of India (ICSI), through a representation dated 23 September 2026 addressed to the Secretary, Ministry of Corporate Affairs, has sought uniform recognition of Practising Company Secretaries for representing parties, certifying, attesting and filing documents before authorities administering the Partnership Act, 1932. ICSI stated that administration of the Act is largely undertaken through State Registrars of Firms and State-specific online platforms, where filings are generally handled by professionals such as advocates and chartered accountants, but there is no uniform framework recognising Practising Company Secretaries. The Institute highlighted that Company Secretaries already perform certification, representation and compliance functions under major regulatory laws, including the Companies Act, 2013, the Limited Liability Partnership Act, 2008 and the Insolvency and Bankruptcy Code, 2016. ICSI has requested the Ministry to encourage State Governments, Registrars of Firms and administrators of digital registration platforms to recognise Practising Company Secretaries for partnership-related certification, attestation and filing. It has also referred to representations made to the Registrars of Firms in Kerala and Maharashtra. According to ICSI, such recognition would improve professional representation, regulatory filings and legal compliance while supporting Ease of Doing Business and Ease of Compliance.
THE INSTITUTE OF COMPANY SECRETARIES OF INDIA
IN PURSUIT OF PROFESSIONAL EXCELLENCE
Statutory body under an Act of Parliament
(Under the jurisdiction of Ministry of Corporate Affairs)
CS Pawan G. Chandak
PRESIDENT
ICSI: G&CL: MCA: SEPT:01/2026
September 23, 2026
Dr. Pallavi Jain Govil
Hon’ble Secretary
Ministry of Corporate Affairs
Government of India
New Delhi
Respected Madam,
Subject: Representation for Authorising Company Secretary in Practice to Represent Parties before Authorities under the Partnership Act, 1932
Greetings from the Institute of Company Secretaries of India!
At the outset, the Institute expresses its sincere appreciation for the Ministry’s continued efforts towards strengthening the regulatory framework, promoting Ease of Doing Business and facilitating a compliance ecosystem supported by competent professionals and digital governance initiatives.
The Institute wishes to draw the attention of the Ministry to the fact that administration of the Partnership Act, 1932 is largely undertaken through State Registrars of Firms and State-specific online platforms. In several jurisdictions, filings and registration-related activities under the Act are carried out through recognised professionals such as Advocates and Chartered Accountants. However, there exists no uniform framework recognising Practising Company Secretaries for certification, attestation and filing of partnership-related documents, notwithstanding their extensive expertise in business laws and regulatory compliance.
It is pertinent to note that Company Secretaries play a critical role in the Indian regulatory framework and are statutorily recognised under several major legislations, including the Companies Act, 2013, the Limited Liability Partnership Act, 2008, the Insolvency and Bankruptcy Code, 2016, securities laws and indirect tax laws. Members of the profession are routinely entrusted with certification, representation and compliance functions before regulatory authorities, tribunals and other statutory forums.
Given their training and professional competence, Company Secretaries are well-equipped to assist partnership firms in matters relating to registration, changes in constitution, admission or retirement of partners, dissolution, maintenance of statutory records and other compliance requirements under the Partnership Act.
ICSI Submission:
In view of the foregoing, the Institute respectfully requests the Ministry to
– advise and encourage State Governments, Registrars of Firms and administrators of digital registration platforms to recognise Practising Company Secretaries for certification, attestation and filing of documents under the Partnership Act, 1932.
– consider appropriate policy measures and regulatory interventions that may facilitate uniform recognition of Practising Company Secretaries across jurisdictions in matters relating to partnership firm registrations and compliance.
Further, we wish to submit that representations have been made to the Hon’ble Registrar of Firms, Kerala, seeking recognition of Company Secretaries in Practice as Attestation Officers on the e-GROOPS Portal, and to the Hon’ble Registrar of Firms, Maharashtra, for permitting Company Secretaries in Practice to undertake certification, filing, and attestation of partnership registration documents before the Registrar of Firms, Maharashtra. The representations are annexed as Annexure I & II.
In this regard, we respectfully request you to kindly advise the Hon’ble Registrar of Firms, Kerala and the Hon’ble Registrar of Firms, Maharashtra to favourably consider and accede to our representations for recognizing Company Secretaries
Justification:
It is pertinent to note that Company Secretaries play a critical role in the Indian regulatory framework and are statutorily recognised under several major legislations, including the Companies Act, 2013, the Limited Liability Partnership Act, 2008, the Insolvency and Bankruptcy Code, 2016, securities laws and indirect tax laws.
Members of the profession are routinely entrusted with certification, representation and compliance functions before regulatory authorities, tribunals and other statutory forums. Given their training and professional competence, Company Secretaries are well-equipped to assist partnership firms in matters relating to registration, changes in constitution, admission or retirement of partners, dissolution, maintenance of statutory records and other compliance requirements under the Partnership Act.
The absence of uniform recognition across States has resulted in varying practices that restrict professional participation and create avoidable disparities in the compliance framework governing partnership firms.
Extending similar recognition under the Partnership Act would provide partnership firms with access to competent professional representation, improve the quality of regulatory filings, minimise procedural deficiencies, reduce the burden on the authorities through accurate submissions, and promote greater legal compliance. It would also be aligned with the Government’s vision of Ease of Doing Business and Ease of Compliance by expanding the pool of recognised professionals available to assist businesses.
We shall be happy to provide any further information or clarification that may be desired in this regard.
Thanking you
Yours faithfully
(CS Pawan G. Chandak)
President
The Institute of Company Secretaries of India
