SEBI Invites Applications for Empanelment of Forensic Auditors

The Securities and Exchange Board of India (SEBI) has issued a Notice Inviting Applications (NIA) for the empanelment of forensic auditors for a period of three years. Applications are to be submitted online via the Central Public Procurement Portal by December 15, 2025, and successful applicants will be evaluated through a two-stage process, including document scrutiny and presentations before a Quality Assessment Committee (QAC). Eligible applicants must have a minimum of five years’ forensic audit experience, a qualified team of partners/directors and employees, and past experience in at least six forensic audits, with three for regulatory or government bodies. The empanelled firms will conduct investigations, analyze financial statements, maintain confidentiality, adhere to timelines, and provide legally defensible reports. Fees for assignments range from INR 10–30 lakhs, depending on the size and complexity of the company audited. SEBI retains discretion to accept or reject applications, substitute underperforming auditors, and resolve disputes via arbitration in Mumbai.

Securities and Exchange Board of India

1. DATA SHEET

2. INTRODUCTION

2.1. Securities and Exchange Board of India (hereinafter referred to as ) invites applications from eligible / body corporates (hereinafter referred to as s ) for empanelment to take up assignments relating to forensic audit of financial statements of listed companies.

2.2. / body corporates, as per the eligibility criteria prescribed in para 5 of this NIA may submit their applications as per the guidelines mentioned hereunder for empanelment

3. TERMS OF REFERENCE & SCOPE OF FORENSIC AUDIT

This NIA pertains to the process of empanelment of forensic auditors. The detailed Terms of Reference & Scope of Forensic Audit shall be defined on a case-to-case basis at the time of assignment. However, an indicative broad Terms of Reference & Scope of Forensic Audit is outlined below for reference.

3.1. Case Investigation and Analysis:

3.1.1. Conduct detailed forensic examination of cases referred by SEBI within the scope determined by SEBI.

3.1.2. Review and analyse relevant financial statements, books of accounts, statutory filings, corporate records, minutes, agreements, and other relevant documentation, as required.

3.1.3. Apply advanced forensic techniques, usage of tools, wherever required.

3.2. Data Collection and Segregation:

3.2.1. Collect, collate, and segregate data from various sources including listed companies, intermediaries, registrars, depositories, banks, auditors, other stakeholders etc.

3.2.2. Ensure chain-of-custody protocols and evidentiary standards are maintained in handling sensitive information.

3.3. Reporting and Documentation:

3.3.1. Prepare draft findings during the course of investigation, as required by and in such manner as specified by SEBI.

3.3.2. Reports should be presented in a clear, concise, and legally defensible manner, suitable for regulatory and enforcement proceedings.

3.4. Interaction with SEBI Officers:

3.4.1. Participate in meetings, presentations, and discussions with SEBI officers to explain findings, methodology, and recommendations.

3.4.2. Provide clarifications, supporting documentation, and expert views as required by SEBI.

3.5. Compliance and Confidentiality:

3.5.1. Maintain strict confidentiality of all assignments and information accessed during the course of work.

3.5.2. Avoid conflict of interest situations by disclosing prior associations with entities under investigation.

3.6. Timelines and Deliverables:

3.6.1. Adhere to timelines specified by SEBI for each assignment.

3.6.2. Submit periodic progress updates and final reports as required by and in such manner as specified by SEBI.

3.7. Additional Support: Provide support in deposition, as and when required.

4. EMPANELMENT CRITERIA AND PROCEDURE

4.1. A two- stage evaluation process is being adopted.

4.1.1. The first stage will involve scrutiny of applications received on CPP Portal in accordance with the eligibility criteria specified at para 5 of this NIA for empanelment.

4.1.2. In the second stage, the applicants who have fulfilled the eligibility criteria would be required to make a presentation covering areas specified at para 7 of this NIA before a Quality Assessment Committee ( QAC ). The QAC would evaluate the aforesaid applicants based on their presentation and recommend them to the Competent Authority in SEBI for empanelment.

4.2. The date, time and venue of the presentation will be posted on the SEBI website (https://sebi.gov.in) and also communicated through email id shared by the applicants who have fulfilled the eligibility criteria as specified at para 5 of this NIA for empanelment.

4.3. The applicant scoring above 70 marks out of 100 shall be recommended to the Competent Authority in SEBI, for empanelment.

5. ELIGIBILITY CRITERIA FOR EMPANELMENT

5. The Applicant

5.1. Should have minimum 5 years of experience in the field of forensic audit as on September 30, 2025;

5.2. Should have a minimum of 5 Partners/ Directors as on September 30, 2025, out of which at least 3 Partners/ Directors should be actively involved in forensic audit related work and should also have minimum 3 years of experience in the field of forensic audit;

5.3. Should have employed at least 10 persons (full time) as on September 30, 2025, having relevant qualification, experience and expertise in the field of audit, out of which at least 5 employees* should have qualification relevant to the forensic audit (such as Certified Fraud Examiner, ICAI certification on Forensic Accounting and Fraud Detection, Diploma in Forensic Audit from ICMAI, etc.);

* For the purpose of empanelment of forensic auditors, employees for consideration shall include partners/ directors.

5.4. Proposed team for forensic audit assignment of SEBI should consists of minimum 4 persons, out of which minimum 3 should be Chartered Accountants/ Cost Accountants having experience of minimum 3 years in the field of forensic audit and should also have qualification relevant to the forensic audit (such as Certified Fraud Examiner, ICAI certification on Forensic Accounting and Fraud Detection, Diploma in Forensic Audit from ICMAI, etc.);

5.5. The applicant should have had experience of undertaking at least 6 forensic audits (total) in last 3 financial years out of which at least 3 forensic audits should be undertaken upon assignment by the Regulatory body/ Government Agency/ Public Sector Enterprise it is empanelled with;

5.6. Total revenue of the firm/ body corporate from forensic audit assignments in the last 3 financial years (2022-23, 2023-24 and 2024-25) must be at least INR 50 lakhs; and

5.7. Should have branches in at least 2 cities viz. Ahmedabad, Bengaluru, Chennai, Delhi, Hyderabad, Kolkata, Mumbai and Pune.

6. SUBMISSION OF APPLICATION ON CPP PORTAL

6.1. Applications are required to be submitted as per the following directions:

6.1.1. Applications shall be submitted through online on Central Public Procurement Portal (CPP Portal) website: https://eprocure.gov.in/eprocure/app.

6.1.2. The following documents shall be submitted for the purpose of scrutiny of applications as mentioned at para 4.1. of this NIA:

a. Application form and other information/ data as per Annexure I.

b. Applicants are advised to submit the required information/ data in PDF and MS excel formats, wherever required, and in the format specified in the Checklist of documents placed at Annexure II.

c. Undertaking as per Annexure III.

6.1.3. Applicants are advised to follow the following documents on the CPP Portal for necessary guidance:

a. Bidders Manual Kit

(https://eprocure.gov.in/eprocure/app?page=BiddersManualKit&ser  vice=page)

b. Frequently Asked Questions (FAQs)

(https://eprocure.gov.in/eprocure/app?page=FAQFrontEnd&service =page)

c. Guidelines for Hassle Free Bid Submission documents. (https://eprocure.gov.in/cppp/hasslefreebidsubmission.pdf)

6.1.4. The application to be submitted for empanelment process on CPP Portal shall be open till December 15, 2025 17:00hrs.

6.1.5. It may be noted that applications received in any other manner other than referred above or after the aforesaid due date are liable to be summarily rejected.

7. EVALUATION BY THE QUALITY ASSESSMENT COMMITTEE ( QAC )

The QAC would evaluate the applicants who have fulfilled the eligibility criteria, based on their presentation, covering the areas specified below and recommend them to Competent Authority in SEBI for empanelment. The marks for evaluation of the aforesaid applicants in respect of each criterion has been indicated against each section below:

8. PROCEDURE FOR EMPANELMENT

8.1. The applicant scoring the marks above 70 marks out of 100 marks would be recommended to the Competent Authority in SEBI for empanelment.

8.2. The decision for empanelment of an applicant shall be taken by the Competent Authority in SEBI based on recommendations by the QAC. The decision of Competent Authority in SEBI, shall be final and binding on all applicants.

8.3. The Competent Authority in SEBI reserves the right to accept or reject any or all the applications without assigning any reason thereof.

8.4. The empanelment shall be valid for a period of three (03) years from date of publication of list of empaneled forensic auditors on SEBI website.

9. FEES FOR ASSIGNMENT POST EMPANELMENT

9.1. Upon successful completion of the forensic audit assignment and upon acceptance of the forensic audit report by SEBI, the forensic audit firm/ body corporate will be paid fees in the range of INR 10 lakhs INR 30 lakhs* exclusive of statutory taxes.

9.2. The exact amount of fees paid within the aforesaid payment range would depend on following two factors:

a. No. of years for which forensic audit is conducted.

b. Size of the listed company (as categorized into Large cap, Mid cap and Small cap, in line with SEBI Circular SEBI/HO/IMD/DF3/CIR/P/2017/114 dated October 6, 2017) for which forensic audit is conducted.

*In case of exceptional circumstances, if the Competent Authority is satisfied then the fees paid to the forensic auditor can exceed INR 30 Lakhs as mentioned above.

10. SOLVENCY CERTIFICATE

The applicant shall furnish solvency certificate issued by their banker, specifically for the purpose of carrying out the forensic audit assignment, for an amount equal to INR 10 Lakhs.

11. DISQUALIFICATION

11.1. Application shall not be considered where disciplinary action/ proceedings has been taken/ initiated against the applicant, its partners/ directors/ employees, by any Regulatory body/ Government Agency/ Public Sector Enterprise/ Any Court of Law during the past 5 years. The reckoning date for this purpose is the date of submission of application on CPP Portal by the applicant. A signed Declaration by the Authorized signatory in this regard should be submitted along with the application.

11.2. In case, it is found that during the course of the empanelment or at any time before or during the forensic audit assignment or after its execution, that one or more of the terms and conditions laid down in this NIA has not been met by the applicant, or the applicant has made material misrepresentation or has given any materially incorrect or false information, the applicant shall be disqualified for any assignments.

11.3. Further, during the course of forensic audit assignment, at any point of time, if SEBI (at its discretion) is of the opinion that the empaneled firm(s)/ body corporate(s) are not performing up to the expectations of SEBI, then SEBI shall have the right to substitute the empaneled firm(s)/ body corporate(s) with another firm(s)/ body corporates(s), as SEBI may deem fit.

11.4. SEBI reserves the right to accept or reject any or all the applications at any stage without assigning any reason thereof.

12. ARBITRATION

Any disputes between the empaneled firm/ body corporate and SEBI shall be settled amicably. In case, parties are not able to resolve any dispute or differences, the same shall be referred to arbitration. The arbitration shall be conducted in accordance with the provisions of the Arbitration and Conciliation Act, 1996 or any statutory modifications or re-enactment thereof and the rules made there under and for the time being in force. The place of arbitration shall be Mumbai.