CA Final Audit amendments for Nov 2026: 8 RTP updates
The CA Final Audit amendments for Nov 2026 are the eight items in Part I (Academic Update) of ICAI's Paper 3 RTP for November 2026 (PDF) (opens in a new tab): five for NBFC audit in Chapter 14 and three for professional ethics in Chapter 19. The NBFC items cover the RBI's 2026 registration exemption, NBFC-MFIs, capital, risk weights and provisioning. The ethics items are an amended Clause (9) of the First Schedule, a new Clause (5) of the Second Schedule and the 60 tax audit limit, now counted per financial year. ICAI's cut-off is 30 April 2026.
Audit is on Friday, 6 November 2026, the last Group I paper (timetable). Below: each change, what to write, and the two RTP cases that test them.
CA Final Audit amendments for Nov 2026 at a glance
| # | Chapter | What changed (ICAI's RTP, Part I) | Source or study material page |
|---|---|---|---|
| 1 | 14: NBFCs | Registration exemption for "Unregistered Type I" NBFCs below ₹1,000 crore | RBI Registration Amendment Directions, 2026 (issued 29 April 2026, effective 1 July 2026) |
| 2 | 14: NBFCs | NBFC-MFI that misses the criteria for four consecutive quarters must give the RBI a remediation plan | RBI circular DoR.FIN.REC.25/03.10.038/2025-26, 6 June 2025 |
| 3 | 14: NBFCs | Minimum capital ratios by layer (Tier 1, CRAR, CET1, leverage) | RBI Capital Adequacy Directions, 2025 |
| 4 | 14: NBFCs | Risk weights for high-quality infrastructure loans; ROU assets added to "other assets" | Risk-weight table, page 14.94 |
| 5 | 14: NBFCs | Standard asset provisioning for NBFC-ML and NBFC-UL | Page 14.99 |
| 6 | 19: Ethics | Clause (9), Part I, First Schedule now refers to sections 139 to 141 of the Companies Act, 2013 | Page 19.68 |
| 7 | 19: Ethics | New Clause (5), Part II, Second Schedule | Page 19.109 |
| 8 | 19: Ethics | 60 tax audit limit applies per financial year, with five rules | Page 19.111 |
ICAI's study material notice (PDF) (opens in a new tab) lists, for Paper 3, the November 2024 edition (Reprint August 2025 onwards) plus the Academic Update/RTP November 2026. There is no separate Audit amendment PDF: ICAI's Final Amendments/Developments page (opens in a new tab) has updates only for DT and IDT.
The cut-off: what "applicable" means for Audit
Anything a regulator issued up to 30 April 2026 is in. ICAI's Study Guidelines for Paper 3, on page 108 of the Group I RTP volume (PDF) (opens in a new tab), say notifications, circulars, rules and guidelines "issued by Regulating Authority up to April 30th, 2026 will be applicable": the six-month rule.
So the RBI's Registration Amendment Directions, issued on 29 April 2026, are in, though they take effect only from 1 July 2026.
NBFC registration exemption: the 2026 amendment
Non-deposit-taking NBFCs with no public funds, no customer interface and an asset size below ₹1,000 crore are now exempt from registration under sections 45-IA and 45-IC of the RBI Act.
The three categories ICAI gives:
| Category | Customer interface | Public funds | Asset size | RBI registration |
|---|---|---|---|---|
| Unregistered Type I | None | None | Below ₹1,000 crore | Exempt |
| Type I NBFC | None | None | Above ₹1,000 crore | Mandatory (CoR) |
| Type II NBFC | Permitted | Permitted | Any | Mandatory (CoR) |
Existing NBFCs that qualify, including those registered as Type I, can apply for deregistration by 31 December 2026.
What to write: the three conditions, the sections exempted (45-IA and 45-IC) and the exit route (deregistration by 31 December 2026), then apply each condition to the facts.
NBFC-MFI: the remediation plan
An NBFC-MFI that fails to keep the qualifying criteria for four consecutive quarters must approach the RBI with a remediation plan, under the RBI circular of 6 June 2025 that ICAI cites.
ICAI restates the definition: a non-deposit-taking NBFC with at least 60% of its total assets (net of intangible assets), on an ongoing basis, in microfinance loans. Some older notes online give a different percentage; use ICAI's 60%.
NBFC capital, risk weights and provisioning
ICAI replaces the capital requirements text with a layer-wise table, under the RBI's Prudential Norms on Capital Adequacy Directions, 2025.
| NBFC | Minimum Tier 1 | Minimum CRAR | Extra |
|---|---|---|---|
| Lending mainly against gold jewellery (50% or more of financial assets), any layer | 12% | 15% | Tier 2 ≤ 100% of Tier 1 |
| Middle Layer and above (other than gold) | 10% | 15% | Tier 2 ≤ 100% of Tier 1 |
| Upper Layer | as Middle Layer | as Middle Layer | CET1 at least 9% |
| Top Layer | as Upper Layer | as Upper Layer | Higher charge set by the RBI |
| Base Layer (other than gold) | Not prescribed | Not prescribed | Leverage ratio not above 7 |
Risk weights: loans to high-quality infrastructure projects carry 75% where the borrower has repaid at least 2% of the sanctioned project debt, and 50% where it has repaid at least 5%. ROU assets now sit under "other assets" at 100%.
Standard asset provisioning: NBFC-ML at 0.40% of the outstanding (including microfinance loans). NBFC-UL by category: individual housing and SME loans 0.25%; teaser-rate housing loans 2.00%; CRE-RH 0.75%; other CRE 1.00%; all other loans 0.40%. ICAI's own illustration: ₹200 crore of individual housing loans, ₹50 crore of CRE and ₹100 crore of other loans need ₹0.50 + ₹0.50 + ₹0.40 = ₹1.40 crore.
ICAI also notes an extra 5% specific provision per restructuring under a resolution plan (capped at 100%), written back once the borrower repays at least 20% without slipping into NPA.
What to write: state the layer first, then its ratio or rate, then the working.
Ethics: Clause (9) and the new Clause (5)
Clause (9) of Part I of the First Schedule now reads: "accepts an appointment as auditor of a company without first ascertaining from it whether the requirements of Section 225 of the Companies Act, 1956 (1 of 1956), or sections 139 to 141 of the Companies Act, 2013 or any other law pertaining to appointment of auditors for the time being in force, in respect of such appointment have been duly complied with".
A new Clause (5) of Part II of the Second Schedule reads: "acts as an auditor of the company in contravention of the provisions of the Companies Act, 2013".
What to write: quote the clause by number and Schedule, and in an appointment case cite sections 139 to 141 of the 2013 Act, not only the 1956 Act. Apply it to the facts, then conclude in one line. By our count, ethics carried 22–25 marks in each of ICAI's last four papers (CA Final Audit chapter-wise weightage), so wording a clause correctly matters.
The 60 tax audit limit, now per financial year
The limit stays at 60 per member, now counted per financial year. ICAI's five rules:
- 60 per member, counted per financial year.
- One aggregate limit for audits accepted and signed as an individual and as a partner of any firm: no member can sign more than 60 tax audit reports in a financial year.
- A partner's limit can't be distributed or shared between partners.
- Not counted: audits under clauses (c), (d) and (e) of section 44AB, for persons covered by sections 44AE, 44ADA and 44AD.
- A revised tax audit report isn't counted again.
How ICAI asks it: the RTP's MCQ 1
PNBM & Associates has four partners. Partner Chetan signed 68 tax audit reports under section 44AB, excluding 44AD, 44ADA and 44AE audits. He argues the firm's ceiling is 240, so any partner may cross 60.
ICAI's answer is (b): Chetan is guilty, because the ceiling of 60 applies to each member individually, whatever the number of partners. Rule 3 above settles it: the limit can't be shared. When you count, leave out 44AD, 44ADA and 44AE audits and revised reports.
How ICAI asks the NBFC change: RTP Question 17
Facts. XYZ Investments Pvt. Ltd. only holds shares and debentures of group companies. It takes no public deposits or public funds, has no customer interface and doesn't plan either. Its assets are ₹850 crore. It holds a CoR as an NBFC-BL because it met the 50-50 test. The auditor, planning the FY 2026-27 audit, must say whether it still needs the CoR.
ICAI's answer, in three blocks:
- Provision: section 45-IA requires a CoR, subject to exemptions. The 2026 Amendment Directions exempt an "Unregistered Type 1 NBFC" that has no public funds, no customer interface, assets below ₹1,000 crore, and runs on that basis as a conscious, long-term business model. Conditions include an annual Board resolution and a disclosure in the Notes to Accounts.
- Application: XYZ meets every condition; ₹850 crore is below ₹1,000 crore.
- Conclusion: XYZ is eligible for the exemption, but its existing CoR doesn't lapse automatically. It may apply to the RBI to surrender it by 31 December 2026, subject to the RBI's approval.
That last line is the trap: "exempt, so no CoR" misses ICAI's conclusion.
What's not part of the Nov 2026 Audit amendments
- Anything issued after 30 April 2026. Later changes you read about in the news are outside ICAI's cut-off.
- A separate "applicability" list for Audit. As of 29 October 2026, ICAI's BOS announcements (opens in a new tab) carry no separate November 2026 "Applicability of Standards/Guidance Notes/Legislative Amendments" notice for Final. The applicability statement is the one in the Group I RTP volume quoted above.
Revision plan: three weeks to 6 November
| When | What to do with the amendments |
|---|---|
| 14–20 Oct | Read Part I of the RTP once. Make one sheet from the tables in this post: three NBFC categories, the capital table, the provisioning rates, Clauses (9) and (5), the five tax audit rules |
| 21–27 Oct | Write RTP Question 17 and MCQ 1 by hand and check them against ICAI's answers. Do one full Audit paper under exam time |
| 28 Oct–1 Nov | FR week. Keep 20 minutes a day for the sheet. On 31 Oct, go through your ethics clause table with the three updates |
| 5 Nov | Read the sheet once in the morning. No new material |
How to fit amendments into every paper's revision is in how to revise amendments for CA exams, and the full 10-day Audit plan is in our CA Final Audit preparation strategy. For the question types ICAI repeats, see CA Final Audit important questions.
Frequently asked questions
What is the cut-off date for CA Final Audit amendments for Nov 2026?
30 April 2026. ICAI's Study Guidelines for Paper 3 say notifications, circulars, rules and guidelines issued by a regulating authority up to that date apply (Group I RTP, PDF (opens in a new tab)).
Where is the CA Final Audit amendments PDF for Nov 2026?
In Part I (Academic Update) of ICAI's Paper 3 RTP (PDF) (opens in a new tab), listed on ICAI's Final RTP page (opens in a new tab). All six Nov 2026 RTPs are linked in CA Final RTP Nov 2026 with answers.
Are the CA Final Audit amendments for May 2026 the same as Nov 2026?
No. ICAI's May 2026 applicability notice (PDF) (opens in a new tab) set the Paper 3 cut-off at 31 October 2025; November 2026 uses 30 April 2026, with the eight items above. Cut-offs for every attempt are in what's applicable for your CA attempt.
Is the RBI's 2026 NBFC registration amendment applicable though it starts on 1 July 2026?
Yes. ICAI's cut-off covers guidelines "issued" up to 30 April 2026. These Directions were issued on 29 April 2026, and ICAI includes them in the RTP's Academic Update.
Can a partner sign more than 60 tax audit reports if the firm's total is within limit?
No. ICAI's RTP says the limit is per member per financial year and can't be shared between partners, as its MCQ 1 shows.
Practise the amendments in a full Audit paper
An amendment in the exam hides inside a case. Our CA Final Audit mock tests are 3 full-syllabus papers set at the real ICAI exam standard, on the latest pattern, and they test every amendment applicable for November 2026. You write by hand, scan the pages into one PDF and upload it; the checked copy gives the reason for every mark cut, with the correct line to write. Mock Test 1 has preview pages open on that page. The FR changes are in our sister post, CA Final FR amendments for Nov 2026.
For every paper and level, see our CA test series and CA mock tests.