Sections 20A explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Chapter IVA, sections 20A to 20D, was inserted by the Chartered Accountants, the Cost and Works Accountants and the Company Secretaries (Amendment) Act, 2022. It requires every firm to be registered with the Institute, creates a Register of firms, lists when a firm is removed and gives a one-month review before the Council. As per the ICAI 2022 edition and S.O. 2184(E) dated 10 May 2022, the Chapter is enacted but not yet brought into force, so it is explained here as enacted text.
This article is as per the Act as printed in the ICAI edition of 2022 (amended up to the Chartered Accountants, the Cost and Works Accountants and the Company Secretaries (Amendment) Act, 2022). The edition prints the date of coming into force of Chapter IVA as a blank, and its cover lists the Chapter as yet to be notified. A later commencement notification should be checked, together with later amendments and notifications.
Enacted, not yet in force: every firm shall be registered with the Institute on an application by any partner or owner, the Council may refuse an identical or similar name or an "undesirable" registration, the Council keeps a Register of firms, removes a firm in five listed cases, and a refused firm may seek review within one month. Today, no Act provision requires registration of firms; the Act deals with firms through the definition in section 2(1)(ca), the firm-name proviso to section 7 and section 27 on branch offices.
Where the commencement trap lies
S.O. 2184(E) dated 10 May 2022 brought into force most of the 2022 Amendment Act but not Chapter IVA. The edition agrees: its cover lists Chapter IVA as yet to be notified, and the footnote to the Chapter reads "came into force w.e.f." with a blank date. Because there is no earlier wording to compare, the position is simple: there is no 2006 text for these sections. The Act as in force today has no firm-registration scheme, and the 2022 Chapter describes what the scheme will be when it is brought into force. If you are preparing for that change, a partnership firm registration adviser can help you plan the firm's constitution and records.
Section 20A: registration of firms
Section 20A says that every firm shall be registered with the Institute on an application made to the Council, by any partner or owner of the firm, in such manner and subject to such terms and conditions as may be prescribed. "Prescribed" means prescribed by regulations made under the Act, so the form, fee and procedure are not in the section.
"Firm" is defined in section 2(1)(ca): a firm has the meaning in section 4 of the Indian Partnership Act, 1932 and includes a limited liability partnership under the LLP Act, 2008 or a sole proprietorship, registered with the Institute. The words "any partner or owner" in section 20A mirror that range of firms: partnership, LLP and proprietorship. For the general law, see the Indian Partnership Act, 1932 and the LLP Act, 2008.
Proviso: grounds for refusal. The Council may refuse to register a firm if:
- the name is identical or similar to the name of any other firm already registered;
- the name is in use by any firm within or outside India; or
- in the opinion of the Council, registration of the firm is undesirable.
The third ground rests on the opinion of the Council. The section does not define "undesirable". The proviso uses "may", so refusal is a discretion, not a duty.
Section 20B: the Register of firms
| Sub-section | Rule |
|---|---|
| (1) | the Council shall maintain, in such manner as may be prescribed, a Register of firms |
| (2) | the Register shall include such particulars about the firm, including details of pendency of any actionable information or complaint or imposition of penalty against it under Chapter V, in such form and at such intervals as may be prescribed |
| (3) | the Council shall publish, in the prescribed manner, a list of firms registered with the Institute as on 1 April of each year, or at any such interval as the Council decides, and make the list available to such persons, in such form and on payment of such amount as may be prescribed |
The Register of firms mirrors the Register of members in section 19. Sub-section (2) ties it to the disciplinary system: pending actionable information or complaints and penalties against the firm under Chapter V are to be recorded. The word "actionable" comes from the 2022 text of section 21, which is also not yet in force; see the article on section 21. Section 2(1)(g) already defines the Register to include the Register of firms under section 20B, and section 15B(d) lists maintaining it among the Institute's functions; both are in force as words, though the Register depends on this Chapter.
Section 20C: removal from the Register of firms
The Council shall remove from the Register of firms the name of any firm:
| Clause | Ground |
|---|---|
| (a) | which is dissolved or liquidated |
| (b) | from which a request has been received to that effect |
| (c) | which is declared insolvent or bankrupt under the Insolvency and Bankruptcy Code, 2016 and remains undischarged |
| (d) | which has been debarred from undertaking any activity or activities relating to the profession of a chartered accountant in practice under any law for the time being in force or by any competent court |
| (e) | in respect of which an order for removal has been passed under the Act |
The verb is "shall", so removal on these grounds is not left to discretion. Clause (e) points to orders under Chapter V, such as an order of the Disciplinary Committee, which the later articles explain. Compare the removal of members in section 20, where the Council "may" remove on some grounds and "shall" on others.
Section 20D: review before the Council
- 20D(1): any firm aggrieved by the decision for refusal of registration may apply for review before the Council within one month from the date of such refusal.
- 20D(2): the Council may, after considering the review application, confirm or set aside the decision or pass such orders as it considers appropriate.
The review lies against refusal of registration only. The Chapter does not provide a review of removal under section 20C. Orders of the disciplinary bodies have their own appeal under section 22G, explained in the article on section 22G.
What the Act provides today for firms
While Chapter IVA is not in force, the Act as it stands deals with firms in these places:
| Provision | What it says |
|---|---|
| Section 2(1)(ca), (eb), (ec) | defines firm, partner and partnership |
| Section 7, proviso | a firm all of whose partners are members in practice may be known by its firm name as Chartered Accountants |
| Section 25 | companies not to engage in accountancy, explained in its own article |
| Section 27 | a chartered accountant in practice, or a firm of such chartered accountants, with more than one office in India must keep each office in the separate charge of a member, and must send the Council a list of offices and the persons in charge |
| The Schedules | professional and other misconduct of members, covered in the Schedule articles |
A worked example
Anand and Beena, both chartered accountants, run a partnership firm. If Chapter IVA were in force, either partner could apply to the Council for registration of the firm in the prescribed manner. The Council could refuse if the proposed name were identical or similar to a registered firm's name. The firm could then apply for review within one month of the refusal. Today, in the absence of a commencement notification, the firm has no registration step under the Act; its obligations on branch offices under section 27 and the firm-name proviso under section 7 continue to apply.
Need help planning for firm registration?
Firms that plan their constitution, name and records ahead are better placed when a registration scheme starts. Our partnership firm registration team can help with the firm's structure and documents, and with checking the current position on commencement.
Key takeaways
- Chapter IVA (sections 20A to 20D) is enacted by Act 12 of 2022 but not yet in force as per the ICAI 2022 edition and S.O. 2184(E); a later notification should be checked.
- Section 20A would require every firm to be registered with the Institute on an application by a partner or owner, with refusal possible for identical or similar names or undesirable registration.
- Section 20B would create a Register of firms recording, among other things, pending information or complaints and penalties under Chapter V.
- Section 20C would require removal of a firm in five listed cases.
- Section 20D would give a one-month review before the Council against refusal.
- Today the Act deals with firms through section 2(1)(ca), the proviso to section 7 and section 27.
Read next
- Sections 19 and 20 of the Chartered Accountants Act, 1949: the Register of members and removal of names
- Section 21 of the Chartered Accountants Act, 1949: the Disciplinary Directorate
- Section 22G of the Chartered Accountants Act, 1949: appeal to the Appellate Authority
- Sections 20A to 20D of the Cost Accountants Act, 1959: registration of firms
Disclaimer: Based on the Chartered Accountants Act, 1949 as printed in the ICAI edition of 2022 (amended up to Act 12 of 2022), read with S.O. 2184(E) dated 10 May 2022, which brought only part of the 2022 amendments into force, as consulted on 3 October 2026. Regulations, rules, Council guidelines, later amendments and commencement notifications should be checked. This article is general information, not legal advice; check the official text before acting.