UCBs: Statutory auditors cannot do internal/concurrent audit (2009 circular)
No longer current — withdrawn, no replacement on file yet
Source: Reserve Bank of India · RBI/2008-09/355 · issued 21 Jan 2009 · ~1 min read
Quick answerRBI bars statutory auditors from also handling internal or concurrent audit assignments for the same Urban Co-operative Bank in the same period. Firms must drop internal/concurrent work before taking up statutory audit. Effective from January 21, 2009.
What changed
RBI clarified that chartered accountants or audit firms cannot simultaneously serve as statutory auditor and internal/concurrent auditor for the same UCB. If a firm is already doing internal/concurrent audit, it must resign that role before accepting the statutory audit mandate for the same financial year.
What it means for you
UCBs must ensure no overlap between statutory audit and internal/concurrent audit assignments. This prevents conflicts of interest and preserves audit independence. Banks need to verify that their appointed statutory auditors have no ongoing internal or concurrent audit engagements with them.
Historical instruction — do not use for current compliance. This is what was required at the time; it no longer reflects current RBI requirements. If no replacement rule is linked above, that only means none is recorded on our register yet — it does not prove no later applicable rule exists. Confirm on the official RBI source below.
What banks were required to do at the time
Review current statutory auditor appointments to confirm they are not also engaged for internal or concurrent audit of the same UCB.
If any overlap exists, require the audit firm to relinquish the internal/concurrent assignment before accepting the statutory audit.
Update your audit engagement letters and internal policies to reflect this prohibition.
Communicate this rule to all branches and audit committees.
Who it affects
Primary (Urban) Co-operative Banks, Chartered Accountants and audit firms serving UCBs, State Governments appointing statutory auditors for UCBs with deposits of Rs 25 crore and above
❓ Common questions
Regulatory timeline
Stated effective dateEffective from January 21, 2009
Decoded by BankPulse2026-06-19 11:05 IST
Status change: withdrawn05 Aug 2026, 04:00 IST
Built from our lineage records — each fact carries its provenance; missing history simply is not shown (never guessed).
Can a CA firm do internal audit for one UCB and statutory audit for a different UCB?
The circular only prohibits the same firm from holding both roles in the same UCB. It does not restrict a firm from doing internal audit for one UCB and statutory audit for another unrelated UCB.
What if our statutory auditor was already doing concurrent audit when this circular was issued?
The instructions are effective immediately. The firm must relinquish the concurrent audit assignment before accepting or continuing the statutory audit for the same year.
📜 Read the original circular — full text as issued by RBI
RBI/2008-09/355
UBD.CO.BPD.35 /12.05.001/2008-09
January 21, 2009
Chief Executive Officers of
All Primary (Urban) Co-operative Banks
Dear Sir / Madam,
Internal assignments in banks by statutory auditors
Please refer to our circular No. UBD. POT. 77/09.06.00/93-94 dated May 31, 1994 on introduction of concurrent audit system in UCBs. The extant guidelines provide that concurrent audit could be carried out by external auditors (professionally qualified Chartered Accountants) or by own staff, at the option of the individual banks. Similarly, some banks may have engaged Chartered Accountants (CAs) for internal audit as well. Further, State Governments are committed to appoint Chartered Accountants for statutory audit of the banks with deposit base of Rs. 25 crore and more, as per the MoU entered into by Reserve Bank of India.
2. In the above context, it is advised that chartered accountants / audit firms should not undertake statutory audit assignment with any UCB while they are associated with the bank for internal / concurrent audit assignments during the same period. In case the firms are associated with internal /concurrent audit assignment, it should be ensured that they relinquish the internal / concurrent audit assignment before accepting the statutory audit assignment during the year.
3. These instructions come into force with immediate effect
Yours faithfully,
(A. K. Khound)
Chief General Manager
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2008-09/355 · issued 21 Jan 2009. The plain-English explanation above is BankPulse’s own independent summary.
Discuss this circular with fellow bankers — reply, upvote what helps, report what doesn’t belong. Be professional; no client data. Views are the commenter’s own, not BankPulse’s.
BankPulse Compliance Evidence Pack — generated 05 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=4779&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
Help us keep this accurate
Found an inaccuracy or have an improvement? Tell us. Every report is reviewed by our team before any change is made — nothing goes live unverified.
Public beta — plain-English informational summaries. Always verify against the official RBI source (circular number cited on every page) before making compliance, credit, treasury, audit, or operational decisions. · Join our WhatsApp channel ↗
BANKPULSE · FREE DAILY BRIEF
Get RBI updates for your role
Every important RBI update, decoded in plain English — for your career, exams & financial awareness.
We collect only your email, name and role, used solely to send your brief — never sold or shared. Withdraw anytime via the unsubscribe link in any email. Independent platform, not affiliated with the RBI. Information, not legal advice.
REPORT AN ERROR · BETA
Spotted an error? Earn 500 BankPulse Credits
Help us stay accurate. If your correction is verified true and approved by our founder, you earn 500 BankPulse Credits — redeemable when the platform monetises.
Reviewed by a human before any credit is awarded. We never change the site from crowd input without verification.
WANT A NEW FEATURE · BETA
What would make BankPulse more useful for you?
Tell us what to build next — a tool, a data view, a role page, anything. We read every suggestion.
Thank you — your ideas directly shape what we build.