Part-Time IA Registration for CAs: A Practical Compliance Checklist

Once You've Decided to Register, Here's Exactly What Follows

If you've worked through the question of whether your practice needs part-time IA registration (see our companion article on where that line actually sits) and concluded that it does, the next question is practical: what does the process and ongoing obligation actually involve? This checklist walks through it in the order it typically needs to happen.

Before You Apply

• Confirm your primary practice qualifies — ICAI membership providing statutory services is explicitly recognised; confirm your specific service mix genuinely fits the "unrelated to securities, no client money handling" test
• Complete NISM Series-X-A and X-B certification — the same qualification bar as full-time IAs applies; there's no reduced certification requirement for part-time status
• Draft your arms-length undertaking — document, in writing, how your IA activity will be segregated from your CA practice before you file, not after
• Design your disclaimer template — prepare the minimum-10-font disclaimer for non-IA invoices in advance (see our dedicated article on this specific requirement)

During the Application

• Arrange your deposit — even part-time IAs must maintain the client-count-linked deposit, lien-marked in favour of IAASB
• Prepare fit and proper declarations — for yourself and any other relevant individuals in your practice
• File through IAASB (BSE) — respond promptly and consistently to any clarificatory queries raised during review

Immediately After Registration — Before Taking On IA Clients

• Build your client agreement and MITC template — every advisory client needs a signed agreement before any advice is given or fee charged
• Set up your risk-profiling process — documented, with client consent obtained on each completed profile
• Finalise your fee structure — AUA or fixed fee mode, within the applicable caps, disclosed clearly in the client agreement
• Update your website and all client-facing materials — SEBI-registered name, registration number, disclaimer, and compliance officer details all need to be displayed correctly
• Set up your record-keeping system — records are required from the first advice-related interaction, not from whenever you get organised

Ongoing Obligations You Need to Track Continuously

• Client-level segregation — ensure no client simultaneously receives both advisory and distribution-linked services through your firm
• Annual compliance audit — completed within 6 months of financial year-end, submitted to IAASB within 1 month of the audit report (not later than 31 October)
• Deposit revision — check annually whether client-count growth requires a higher deposit slab, revised by 30 April
• Complaint disclosure — monthly complaint-status data published on your website within 7 days of month-end
• Ongoing disclaimer compliance — confirm the non-IA disclaimer continues appearing correctly on every relevant invoice and communication, not just at initial rollout

The Checklist Item Most Firms Underestimate: Ongoing Discipline

The application and initial setup, while detailed, are a one-time project. The compliance items in the final section above are recurring, and it's the recurring discipline — not the initial registration — that determines whether a part-time IA practice stays genuinely compliant over time.

Managing This Checklist So You Don't Have To

We support CAs through every stage of this checklist — registration, initial compliance setup, and ongoing annual compliance management — so your part-time IA activity stays compliant without becoming a second full-time job on top of your existing practice.

Ready to move from "we should probably register" to actually getting it done correctly? Anuj Desai & Associates can manage this checklist end-to-end for you.

This article is for general informational purposes and does not constitute regulatory advice specific to any professional's circumstances.