From Big Four to Big Eight, ETLegalWorld

The Clarion Call

On 1st July 2017, at the ICAI Foundation Day & Chartered Accountants Day celebration, Prime Minister Narendra Modi threw down a challenge to India’s accounting profession. Referring to the ‘Big 4’ — the term used for the world’s four biggest audit firms — he pointed out that there are Several accounting firms in India but none of them has managed to find a place among the top global players. His ask was specific: by 2022, India should have a “Big 8,” with four of those eight firms being Indian CA firms. He was direct about it — India was “nowhere in these big four,” despite having the talent and capability to be there. He also spoke about the Power of the Chartered Accountants Signature. 2022 came and went. India turned 80 on 15^th August 2026. The Big Four remained the Big Four. Nine years on, the ambition is still alive, but it has moved from a speech to a slow-grinding policy process — and it is worth asking, soberly, what it will actually take to close the gap.

The Journey So Far: What ICAI and the Government Have Actually Done

It would be unfair to say nothing has moved. The scaffolding has been going up, piece by piece, though far slower than the 2022 deadline implied.

• Multidisciplinary Partnerships (MDP), 2021. ICAI Council, with Central Government approval, notified the Chartered Accountants (Amendment) Regulations 2021, allowing CAs to bring Cost Accountants, Company Secretaries and other qualified professionals together as partners under a single firm. This was meant to let Indian firms offer the same integrated audit-tax-advisory-legal bundle that the Big Four sell globally.
• Merger & Demerger Guidelines, January 2025. ICAI notified the (Merger & Demerger of CA Firms) Guidelines, 2024, giving Indian CA firms a structured, rule-based pathway to merge — including name-freezing provisions, reconstitution filings, and a formal self-service portal process.
• Committee for Aggregation of CA Firms (CACAF). ICAI constituted CACAF in 2024-25, and it has proposed (under Implementation) an “LLP Firm Network Model” that would let an LLP firm where more than half the partners are CAs join an existing larger LLP network as a partner firm.
• The scale of the problem CACAF is working against. Of roughly 1,00,000 firms registered with ICAI, about 70 % are proprietorships, and only around 400 Indian firms have more than 10 partners — a fragmentation problem the Big Four solved decades ago through sustained consolidation.
• Government-level push. In 2025, a high-level PMO meeting chaired by the Principal Secretary to the PM, with the MCA secretary, revenue secretary, and DEA secretary present, was convened specifically to remove hurdles for Indian CA firms to compete globally. The MCA followed with an Office Memorandum on September 17^th 2025 inviting public comments on establishing Indian MDP firms, flagging the absence of integrated end-to-end service models, lack of global networks, fragmented licensing across professions, and restrictions on advertising as the core structural blockers.
• The advertising ban. A government paper has separately flagged that the advertising ban on CAs, company secretaries and lawyers restricts Indian firms from building strong brands, unlike multinational firms which advertise freely abroad.
• What’s at stake commercially. The Big Four and their affiliates currently oversee assignments for a majority of Nifty 500 firms and generate estimated revenues exceeding ₹55,000 crore annually in India — a number that frames just how large the addressable market is, if even one or more Indian firm captured a meaningful share of it.

The direction is right. The pace is not. Almost a decade after the speech, most of this is still guidelines, memoranda, and committees “yet to implement” — not operating multidisciplinary Indian giants with global offices. And crucially, almost everything achieved so far addresses the supply side — how Indian firms are structured. Almost nothing yet addresses the demand side — why clients default to the Big Four in the first place, and what would need to change in law, capital, and market access for that default to shift.

The Framework: Eight Levers That Actually Determine the Outcome

Permission to merge is not the same as the ability to compete. Below is the working framework — eight levers, each addressing a distinct constraint that keeps Indian firms sub-scale, and each one incomplete without the others.

1. Aggregation — local and global, including non-English-speaking markets

• Domestic consolidation (CACAF’s merger guidelines, the proposed LLP Firm Network Model) is only step one. The Big Four’s real moat is a global network — member firms in over 150 countries, including non-Anglophone markets (Germany, Japan, Brazil, the Gulf, Francophone Africa) where language and local regulatory nuance are real barriers to entry.
• An Indian “Big” firm strategy needs a deliberate international affiliation or acquisition program in non-English-speaking geographies, not just Anglophone hubs like the UK, US and Singapore — because that’s where Indian firms are currently weakest and where global clients most need coverage. The key differentiators cud be Mittlestand Audit firms in EU, West Asia, Russia which will be willing to collaborate with Indian CA firms
• ICAI-brokered “twinning” arrangements with mid-sized firms in target countries could accelerate this instead of waiting for organic growth.

2. Reskilling talent — language, AI, and communication, with government and private-sector support

• Scale without capability is just a bigger version of the same problem. Talent needs three specific upgrades: working fluency in client-country languages for the markets targeted under point 1; AI and automation literacy for modern audit, assurance and advisory delivery; and client-facing communication and consulting skills that Indian training has traditionally underinvested in relative to technical accounting depth.
• The scale of this need is already being flagged publicly — India’s growth trajectory is expected to require over one million Chartered Accountants going forward, particularly to support digital payments, startups and modern finance technology. That volume needs to come with reskilling, not just headcount.
• This is a natural public-private partnership: government skilling missions (Skill India, sector skill councils) co-funding structured AI/language/communication tracks run through ICAI, NISM-style institutes, and private L&D providers — rather than leaving reskilling entirely to individual firms’ training budgets. Govt has announced on 15^th August 2026 an Online coaching framework which can also be made available to indigenous Indian CA Firms for skills upgrade in communications, Presentations, EU and Arabic Languages.

3. Delivery model — Front-End/Back-End and Global Delivery Model (GDM)

• The Big Four’s economics work because expensive, client-facing front-end (FE) partners and managers are backed by lower-cost, high-volume back-end (BE) delivery centres — increasingly India itself, ironically, hosts the Big Four’s own GDM/GCC operations.
• Indian firms need to build the same FE-BE architecture domestically: partner-led advisory and relationship management at the front, supported by standardised, tech-enabled delivery centres (in Tier-2/3 India, where cost arbitrage is real) handling audit fieldwork, tax compliance, and data processing at scale.
• This is also the model that makes serving global clients viable economically — a GDM lets an Indian firm win international mandates without pricing itself out against Big Four delivery costs.

4. Independent benchmarking — done by NFRA, not by ICAI

• Quality perception, not just quality itself, is what MNCs and global investors are pricing in when they insist on Big Four audits. A benchmarking or quality-rating mechanism run by the National Financial Reporting Authority — independent of the profession’s own self-regulatory body — would give large Indian firms a credible, third-party signal of audit quality that ICAI-led review cannot fully provide, since ICAI is also the professional body whose members are being reviewed.
• This mirrors how independent regulators (PCAOB in the US, FRC in the UK) audit-inspect firms rather than leaving quality assurance solely to the profession’s own institute — and it is the kind of institutional trust-building that could, over time, loosen the default reflex toward Big Four-only audit clauses.

5. Funding and empanelment support

• Capital: LLPs cannot raise public equity, and partner drawings alone cannot fund technology, international offices, or M&A. ICAI is already working on a report to help homegrown multidisciplinary firms secure financing for global expansion — this needs to convert into actual instruments: dedicated credit lines, DFI participation, or a sandboxed structure for external capital into the non-practice parts of a firm (technology, infrastructure, training) while practice equity stays professional.
• Empanelment: Government, PSU, bank, and regulator empanelment panels should deliberately route a growing share of large audits, IPO due diligence, and advisory mandates to scaled Indian firms — the demand-side complement to any capital or capability building, since without guaranteed deal flow, scale is hard to justify.

6. Marketing and visibility rules

• The advertising ban on CAs, company secretaries and lawyers is a specific, named blocker — it prevents Indian firms from building strong brands and market visibility abroad, while multinational firms operating in India advertise freely. This is a solvable regulatory problem, not a structural one.
• ICAI’s code of conduct needs a calibrated liberalisation — allowing capability communication, thought leadership, and digital marketing within professional-ethics guardrails — so an Indian firm can actually build the kind of brand recognition a global CFO or investor recognises before a pitch meeting, the way “PwC” or “Deloitte” already carries meaning globally.

7. Reciprocity rules laid down by government

• India has historically made no market-access commitments on accounting services under the WTO’s GATS framework, and accounting and audit services in India remain highly restricted for foreign firms, who have navigated this by operating through Indian affiliate structures rather than direct entry. In practice, the Big Four already have full-scale access via their Indian member firms, while Indian firms get no equivalent guaranteed access into the markets the Big Four dominate.
• A reciprocity framework — where deeper market access for foreign accounting networks in India is explicitly linked to equivalent access, recognition, or affiliation rights for Indian firms abroad — gives the government real negotiating leverage it currently isn’t using. This needs to sit with the Ministry of Commerce and MCA jointly, not ICAI alone.

8. Abuse of dominant position — amending the Competition Act

• Under the current Competition Act, 2002, the Big Four cannot easily be held liable for abusing a dominant position because Indian law does not recognise “collective dominance” under Section 4 — even though, functionally, four firms auditing many large Indian companies, actually implies a dominant oligopoly.
• Section 4 of the Competition Act, 2002 doesn’t recognize collective dominance — an enterprise must be proven individually dominant in the relevant market to be liable for abuse. This is the single biggest obstacle to an “abuse of dominant position” case against the Big 4 as a bloc. Article 102 of the Treaty on the Functioning of the European Union explicitly covers abuse “by one or more undertakings” — recognizing collective dominance — but Indian law has no equivalent provision and hence section 5 of Competition Act 2002 needs to amend definition of “Group” beyond the current methodology and thereby bring BIG 4 under definition of Group and equivalence to EU laws.
• A targeted amendment recognising collective dominance (or a sector-specific rule for statutory audit/assurance markets) would give the CCI real teeth to examine exclusionary practices — mandatory Big Four clauses in investor agreements, bundled service arrangements, and referral patterns that structurally lock domestic firms out — rather than relying on case-by-case Section 4 arguments that don’t fit a four-firm oligopoly.

The Honest Conclusion

The 2017 target has already slipped by four years, and the gap between “Big Four” and “Indian Big” is still wide — the Big Four’s India-linked revenues alone exceed ₹55,000 crore a year, a scale no Indian firm is close to individually or even collectively under CACAF. But for the first time, the pieces — MDP regulations, merger guidelines, an aggregation committee, an MCA consultation, and a PMO-level push — are all in motion simultaneously rather than sitting as isolated ideas.

What’s missing is that most of the visible effort so far — points 1 through 3 above — is about making Indian firms bigger and more capable. The harder, less-discussed half of the framework — independent quality benchmarking, funding, marketing freedom, reciprocity, and competition-law reform (points 4 through 8) — is about making the market itself fair enough for a bigger Indian firm to win the mandates that would justify its scale. Without that second half, India could build eight well-merged, well-trained domestic firms and still watch every marquee mandate default to the Big Four out of habit, covenant, or brand trust. Structure alone will not produce a Big Eight; a level market will.

(Views are personal)