HomeCirculars › RBI/2008-09/355

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No longer current — withdrawn, no replacement on file yet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

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

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.
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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.
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