India’s Services Sector: Insights on Regulatory Regime in Professional Services

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India’s Services Sector: Insights on Regulatory Regime in Professional Services iINDIA’S SERVICES
SECTOR
INSIGHTS ON
REGULATORY REGIME
IN PROFESSIONAL
SERVICES


India’s Services Sector: Insights on Regulatory Regime in Professional Services iii

INDIA’S SERVICES SECTOR
INSIGHTS ON REGULATORY REGIME IN
PROFESSIONAL SERVICES
Services Division

Contributors
Dr. Sonia Pant Advisor and Programme Director, NITI Aayog
Mr. Deepak Kumar Deputy Secretary, NITI Aayog
Mr. Shrey Apoorva Consultant (Legal) I, NITI Aayog
Ms. Aishwarya Ajayan Young Professional (Legal), NITI Aayog
Ms. Divya M B Former Young Professional (Legal), NITI Aayog
The Services Division acknowledges the contribution of the Centre for Trade and Investment
Law (CTIL), New Delhi, in drafting Annexure I.
Suggested Citation
NITI Aayog (2026). India’s Services Sector: Insights on Regulatory Regime in Professional Services.
August 2026.
Copyright and Disclaimer
Copyright@ NITI Aayog, 2026
While due care has been taken to ensure that the information contained in this document is
accurate, current, and appropriately referenced, neither NITI Aayog nor the Government of
India assumes any legal liability or responsibility for any loss, injury, claim, or damage of any
kind, including but not limited to incidental, consequential, or indirect losses, arising out of or
in connection with the use of, or reliance upon, the contents of this document.
This document is intended for informational purposes only and may be subject to revision
without prior notice. The views and opinions expressed herein are those of the authors alone
and do not necessarily reflect the official position or policy of NITI Aayog or the Government
of India. The authors make no representation or warranty, expressed or implied, as to the
completeness or comprehensiveness of the coverage of laws, rules, regulations, notifications,
circulars, or judicial precedents, both domestic and international, referred to in this document.

India’s Services Sector: Insights on Regulatory Regime in Professional Services v

India’s Services Sector: Insights on Regulatory Regime in Professional Services ix

India’s Services Sector: Insights on Regulatory Regime in Professional Servicesx

India’s Services Sector: Insights on Regulatory Regime in Professional Services xi
TABLE OF CONTENTS
Executive Summary ����������������������������������������������������������������������������������������������������������������������������1
Chapter 1: Historical Trends and Perspective ������������������������������������������������������������������������������� 3
1.1 Introduction 4
1.2 Evolution of Professional Services 4
1.3 Trends in Professional Services in India 6
1.4 Global Services Trade Architecture 7
Chapter 2: Regulatory Landscape �������������������������������������������������������������������������������������������������11
2.1 Introduction 12
2.2 Horizontal laws affecting establishment 13
2.3 Sector-specific regulatory framework in professional services 16
2.4 Legal Services 20
2.5 Accounting, Auditing and Bookkeeping Services 24
2.6 Architectural Services 35
2.7 Landscape Architectural Services and Urban Planning 40
2.8 Engineering Services 43
2.9 Healthcare Services and Allied Healthcare Services 47
Chapter 3: Stakeholder Consultation �������������������������������������������������������������������������������������������67
3.1 Stakeholder Consultation at NITI Aayog with Regulators,
Industry Experts, and Practitioners 68
3.2 Key Informant Interviews (KIIs) with Regulators, Industry and
Professional Bodies 70
3.3 Consultation with the International Financial Services Centres
Authority (IFSCA) at the GIFT City 70

India’s Services Sector: Insights on Regulatory Regime in Professional Servicesxii
Chapter 4: Regulatory Gaps and Challenges ������������������������������������������������������������������������������ 73
4.1 Legal Services 74
4.2 Accounting, Auditing and Bookkeeping Services 75
4.3 Architectural Services 76
4.4 Engineering Services 77
4.5 Healthcare and Allied Healthcare Services 78
Chapter 5: Insights and Way Forward ������������������������������������������������������������������������������������������81
5.1 Four-pronged strategy to strengthen the professional services sector 82
5.2 Sector-specific insights 85
References ���������������������������������������������������������������������������������������������������������������������������������������94
Annexure I: Country Positions in Select Jurisdictions in Professional Services ������������������� 101
Annexure II: List of Stakeholders who Participated ������������������������������������������������������������������ 117

India’s Services Sector: Insights on Regulatory Regime in Professional Services xiii
List of Boxes
Box 1 Registration under the Shops and Establishments Act
Box 2 Snapshot of the Early History of Foreign Law Firms in India
Box 3 India’s Commitment in Legal Services under GATS and its FTAs
Box 4 Genesis of NFRA
Box 5 List of Qualification Reciprocity Arrangements by ICAI
Box 6 List of Unilateral Agreements/Pilot International Pathway Programme
Box 7 List of MoUs by ICMAI
Box 8
India’s Commitment in Accounting, Auditing and Bookkeeping Services under
GATS and its FTAs
Box 9 India’s Commitment in Architectural Services under GATS and its FTAs
Box 10
India’s Commitment in Landscape Architectural Services and Urban Planning
under GATS and its FTAs
Box 11 List of International Engineering Agreements
Box 12 India’s Commitment in Engineering Services under GATS and its FTAs
Box 13 India’s Commitment in Medical and Dental Services under GATS and its FTAs
Box 14 India’s Commitment in Veterinary Services under GATS and its FTAs
Box 15
India’s Commitment for Services provided by Midwives, Nurses, Physiotherapists
and Paramedical Personnel

India’s Services Sector: Insights on Regulatory Regime in Professional Servicesxiv
List of Figures
Figure 1 Illustrations of modes of supply
Figure 2 Liabilities of the individuals and entities under various forms of establishment
Figure 3 Country-wise Comparison of OECD STRI
Figure 4 Trade in Legal Services
Figure 5 Trade in Accounting, Auditing, and Bookkeeping Services
Figure 6 Trade in Architectural Services
Figure 7 Trade in Engineering Services
Figure 8 Trade in Health Services
Figure 9 Overview of India’s Regulatory Regime in Professional Services
Figure 10 Snapshot of the four-pronged strategy and sector-specific insights

India’s Services Sector: Insights on Regulatory Regime in Professional Services xv
List of Cases
Title Citation
Narendra Sharma & Ors. v. Bar Council of India & Ors. WP (C) No. 1556 of 2024
Lawyers Collective v. Bar Council of India and Ors.
Writ Petition
No.1526/1995
A.K. Balaji v. The Government of India & Ors. AIR 2012 Mad 124
Bar Council of India v. A K Balaji and Ors. 2018 (5) SCC 379
Satyam Computer Services Limited vs. Directorate of
Enforcement
Writ Petition No. 37487
of 2012
All India Council for Technical Education vs. Shri Prince
Shivaji Maratha Boarding House’s College of Architecture
& Ors.
AIRONLINE 2019 SC 1422
Mukesh Kumar Manhar and Anr. v. State Of Madhya Pradesh
and Ors
2005(4) MPHT 270
Council of Architecture v. Mr. Mukesh Goyal & Ors.
AIR 2020 SUPREME
COURT 1736
Sudhir Vohra v. Registrar Of Companies and Ors. AIRONLINE 2018 DEL 51

India’s Services Sector: Insights on Regulatory Regime in Professional Servicesxvi
List of Abbreviations
Abbreviations Description
ACCA Association of Chartered Certified Accountants (UK)
AIBE All India Bar Examination
AICTE All India Council for Technical Education
ANM Auxiliary Nurse Midwives
AYUSH Ayurveda, Yoga, Unani, Siddha and Sowa-Rigpa
B.Arch Bachelor of Architecture
B.E Bachelor of Engineering
B.Plan Bachelor of Planning
B.Sc Bachelor of Science
B.Tech Bachelor of Technology
B.V.Sc. & A.H. Bachelor of Veterinary Science and Animal Husbandry
BCI Bar Council of India
BDS Bachelor of Dental Surgery
BPT Bachelor of Physiotherapy
CA Chartered Accountant
CAGR Compound Annual Growth Rate
CET Common Entrance Test
CMA Cost Accountant
CoA Council of Architecture
COAMSAER
Council of Architecture (Minimum Standards of Architectural Education)
Regulations
CPD Continuing Professional Development
CS Company Secretary
CSEET Company Secretary Executive Entrance Test
DCI Dental Council of India
ECTA Economic Cooperation and Trade Agreement
EFTA European Free Trade Agreement
EU European Union
FEMA Foreign Exchange Management Act
FIPB Foreign Investment Promotion Board
FMGE Foreign Medical Graduate Examination

India’s Services Sector: Insights on Regulatory Regime in Professional Services xvii
Abbreviations Description
FMGL Foreign Medical Graduate Licentiate
FTA Free Trade Agreement
GATE Graduate Aptitude Test in Engineering
GATS General Agreement on Trade in Services
GCC Gulf Cooperation Council
GDP Gross Domestic Product
GIFT City Gujarat International Finance Tech-City
GNM General Nursing and Midwifery / General Nurse and Midwife
GST Goods and Services Tax
GVA Gross Value Added
ICAEW Institute of Chartered Accountants in England & Wales
ICAI Institute of Chartered Accountants of India
ICMAI Institute of Cost Accountants of India
ICSI Institute of Company Secretaries of India
ICWA Institute of Cost and Work Accountants of India
IIA Indian Institute of Architects
ILO International Labour Organisation
IPA Institute of Public Accountants (Australia)
ISACA Information Systems Audit and Control Association
ISCA Institute of Singapore Chartered Accountants
ISOLA Indian Society of Landscape Architects
ITPI Institute of Town Planners India
IVC Indian Veterinary Council
IVA Indian Veterinary Association
JEE Joint Entrance Examination
LLP Limited Liability Partnership
LPO Legal Process Outsourcing
M.Arch Master of Architecture
MBBS Bachelor of Medicine and Bachelor of Surgery
MCA Ministry of Corporate Affairs

India’s Services Sector: Insights on Regulatory Regime in Professional Servicesxviii
Abbreviations Description
MCI Medical Council of India
MDPs Multi-disciplinary Practices
MDS Master of Dental Surgery
MIA Malaysian Institute of Accountants
MoU Memorandum of Understanding
M.Phil Master of Philosophy
MPT Master of Physiotherapy
MRA Mutual Recognition Agreement
M.Sc Master of Science
NATA National Aptitude Test in Architecture
NBEMS National Board of Examination in Medical Sciences
NCAHP National Commission for Allied and Healthcare Professions
NCH National Commission for Homeopathy
NCISM National Commission for Indian System of Medicine
NDC National Dental Commission
NDCA National Dental Commission Act
NEET National Eligibility cum Entrance Test
NExT National Exit Test
NFRA National Financial Reporting Authority
NITI Aayog National Institution for Transforming India
NMC National Medical Commission
NNMC National Nursing and Midwifery Commission
NPM Nurse Practitioner Midwifery
NTA National Testing Agency
NRI Non-Resident Indian
OCI Overseas Citizen of India
OECD Organisation for Economic Co-operation and Development
PIB Press Information Bureau
PIO Person of Indian Origin
QE Qualifying Examination
RBI Reserve Bank of India
SAICA South African Institute of Chartered Accountants

India’s Services Sector: Insights on Regulatory Regime in Professional Services xix
Abbreviations Description
SQM Standards on Quality Management
STRI Services Trade Restrictiveness Index
TCPO Town and Country Planning Organisation
UAE United Arab Emirates
UG Under Graduate
UK United Kingdom
UNSD United Nations Statistics Division
USA United States of America
VCI Veterinary Council of India
WTO World Trade Organisation
WHO World Health Organisation

India’s Services Sector: Insights on Regulatory Regime in Professional Services1
Through the vicissitudes of the last three decades, the services sector stood as the bulwark of
India's economic growth. This observation in India’s Economic Survey 2023-24 underscores
the critical role played by the services sector in driving India’s economic growth. The Economic
Survey 2024-25 further reinforces this view by referring to “services” as an “old war horse” that
continues to anchor India’s GDP growth and overall economic resilience. Notably, in FY24, the
services sector contributed 55% to India’s GDP. India is also the seventh largest exporter of
services globally, accounting for 4.3% of global services exports in 2024. Of this, professional
and management consulting services contributed nearly 20% of India’s total services exports
in 2024-25, thus emerging as a key sub-sector in services.
Professional services are high-value, knowledge-intensive activities that form the backbone
of the services value chain. They play a foundational role in enabling the efficient delivery
of downstream services and are key drivers of job creation and remittance inflows. As such,
professional services serve as critical enablers across the broader services sector and have
immense potential to enhance India’s share in global services trade. However, this potential is
shaped by certain challenges within the existing regulatory framework.
In India, the regulation of professional services is diverse and sector-specific. Disciplines
such as medicine, law, accounting, and auditing (regulated sectors) are governed by well-
defined legal and institutional frameworks, whereas others, such as engineering, landscape
architecture and urban planning, are lightly regulated or lack formal oversight altogether. The
regulated sectors impose various entry and operational conditions for professionals, including
nationality or residency requirements, educational qualifications and licenses, restrictions on
permitted legal forms of establishment, and recognition of foreign qualifications. In the case
of foreign-trained professionals, often additional conditions such as bridge courses, qualifying
exams, and registration with relevant authorities apply.
This report presents a factual assessment of India’s regulatory regime in professional services
with the objective of identifying avenues to boost trade in professional services and unlock the
full potential of its workforce. While the report does not independently interpret regulations, it
draws on extensive stakeholder consultations and in-house research to highlight key challenges
and propose insights and a way forward that has a grounded and practical perspective. The
in-house analysis employs a combination of qualitative and quantitative research methods,
including consultations and key informant interviews with regulators, professional bodies,
think tanks, and industry leaders, as well as trade data sourced from WTO and RBI, along with
comparative insights from OECD and other international sources.
This report analyses each professional services sub-sector through three key dimensions: (1)
laws and regulations that govern professional practice; (2) competencies of professionals,
which include educational qualification and licensing requirements; and (3) restrictions on the
rendering of professional services, including on legal forms of establishment, advertisement
and fee restrictions.
This report is divided into five chapters. Chapter 1 traces the evolution of professional services
in India and the emerging trends. Chapter 2 presents a factual overview of India’s horizontal
EXECUTIVE SUMMARY

India’s Services Sector: Insights on Regulatory Regime in Professional Services 2
and sector-specific regulations in professional services. Chapter 3 details the consultation
process. Chapter 4 highlights key regulatory gaps identified during the consultations. Chapter
5 provides sectoral insights, as drawn from the consultation process, and a way forward to
strengthen India’s professional services ecosystem. It also contains two annexures: Annexure
I highlights country positions in select jurisdictions in professional services. Annexure II lists
the stakeholders who participated.
As India approaches its demographic peak, professional services offer a high-skilled, high-value
avenue for employment, entrepreneurship, and innovation. This report encapsulates a factual
and structural analysis of professional services aiming to serve the following purposes: first,
highlight the existing legal and regulatory framework to support the establishment of business
by both domestic and foreign professional service suppliers; second, identify regulatory
gaps and challenges and thereby enable efforts to enhance the competence and mobility of
professionals; and third, to support India’s multilateral and bilateral trade negotiations. The
four-pronged strategy set out in the diagram below, along with the sector-specific insights,
could increase the efficiency and output in professional services, which will in turn boost
India’s services trade and play a pivotal role in realizing the Vision of Viksit Bharat by 2047.
Continuous Professional
Development for
Professionals
Elevate professional
services within the
services value chain
Adoption of best
practices in professional
services
Advance the emerging
trends in professional
services
Four-pr onged S trategy
Continuous Professional
Development for
Professionals
Elevate professional
services within the
services value chain
Adoption of best
practices in professional
services
Advance the emerging
trends in professional
services
Four-pr onged
Strategy
Sector-specific Insights
Recognition of
Legal Pr ofessionals
other than
Advocates
Regula tory
Harmoniza tion and
Clarity
Professional
Mobility
Revisit A dvertising
Norms
Moderniz e Legal
forms of Pr actice
Skilling of Allied
Legal Pr ofessionals
Pursue Mutual
Recognition
Agreements
(MRAs )
Enhanc e the
regula tory
oversight and
skilling of
bookk eeping
professionals
Phased
Accreditation
Pathways for
Foreign
Professionals
Professional
Examina tion f or
Licensing of
Architects
Streamlined
registration
mechanism
Permit a W ider
Range of L egal
Structur es
Regula tory
framework for
landscape
architects
Pursue MRAs
Regula tory
framework for
engineers in volved
in construction
and r elated
activities
Recognition as
Allied
Professionals
Facilita te the
implementa tion of
the Na tional Exit
Test
Streamline multi-
level regula tory
governanc e of allied
health servic es
Enable int erstate
license portability
Fully oper ationaliz e
the NC AHP A ct,
2021 and skilling of
allied health
professionals
Streamline lic ensing
pathways
Pursue MRAsLegal
Servic es Accounting,
Auditing, and
Bookk eeping
Servic es Architectur al
Servic es Engineering
Servic es Health and
Allied Healt h
Servic es
Continuous Professional
Development for
Professionals
Elevate professional
services within the
services value chain
Adoption of best
practices in professional
services
Advance the emerging
trends in professional
services
Four-pr onged
Strategy
Sector-specific Insights
Recognition of
Legal Pr ofessionals
other than
Advocates
Regula tory
Harmoniza tion and
Clarity
Professional
Mobility
Revisit A dvertising
Norms
Moderniz e Legal
forms of Pr actice
Skilling of Allied
Legal Pr ofessionals
Pursue Mutual
Recognition
Agreements
(MRAs )
Enhanc e the
regula tory
oversight and
skilling of
bookk eeping
professionals
Phased
Accreditation
Pathways for
Foreign
Professionals
Professional
Examina tion f or
Licensing of
Architects
Streamlined
registration
mechanism
Permit a W ider
Range of L egal
Structur es
Regula tory
framework for
landscape
architects
Pursue MRAs
Regula tory
framework for
engineers in volved
in construction
and r elated
activities
Recognition as
Allied
Professionals
Facilita te the
implementa tion of
the Na tional Exit
Test
Streamline multi-
level regula tory
governanc e of allied
health servic es
Enable int erstate
license portability
Fully oper ationaliz e
the NC AHP A ct,
2021 and skilling of
allied health
professionals
Streamline lic ensing
pathways
Pursue MRAsLegal
Servic es Accounting,
Auditing, an d
Bookk eeping
Servic es Architectur al
Servic es Engineering
Servic es Health and
Allied Health
Servic es
Continuous Professional
Development for
Professionals
Elevate professional
services within the
services value chain
Adoption of best
practices in professional
services
Advance the emerging
trends in professional
services
Four-pr onged
Strategy
Sector-specific Insights
Recognition of
Legal Pr ofessionals
other than
Advocates
Regula tory
Harmoniza tion and
Clarity
Professional
Mobility
Revisit A dvertising
Norms
Moderniz e Legal
forms of Pr actice
Skilling of Allied
Legal Pr ofessionals
Pursue Mutual
Recognition
Agreements
(MRAs )
Enhanc e the
regula tory
oversight and
skilling of
bookk eeping
professionals
Phased
Accreditation
Pathways for
Foreign
Professionals
Professional
Examina tion f or
Licensing of
Architects
Streamlined
registration
mechanism
Permit a W ider
Range of L egal
Structur es
Regula tory
framework for
landscape
architects
Pursue MRAs
Regula tory
framework for
engineers in volved
in construction
and r elated
activities
Recognition as
Allied
Professionals
Facilita te the
implementa tion of
the Na tional Exit
Test
Streamline multi-
level regula tory
governanc e of allied
health servic es
Enable int erstate
license portability
Fully oper ationaliz e
the NC AHP A ct,
2021 and skilling of
allied health
professionals
Streamline lic ensing
pathways
Pursue MRAsLegal
Servic es Accounting,
Auditing, an d
Bookk eepin g
Servic es Architectur al
Servic es Engineering
Servic es Health and
Allied Healt h
Servic es

India’s Services Sector: Insights on Regulatory Regime in Professional Services31
Historical Trends
and Perspectives

India’s Services Sector: Insights on Regulatory Regime in Professional Services 41
Historical Trends
and Perspectives
1.1 Introduction
Over the last three decades, the services
sector has played a critical role in driving
India’s economic growth. The Economic
Survey 2024-25 echoes this sentiment by
referring to “services” as an “old war horse”
that continues to anchor India’s GDP growth
and overall economic resilience. Particularly,
in the last decade, services have been a key
growth engine for many middle-income
countries, including India (Economic Survey
2024-25).
As of 2024, India ranks seventh in global
services exports with a 4.3% share, increased
from 2% in 2005. India is preceded by the
United States (13% share), the United Kingdom
(7.3%), Ireland (5.9%), Germany (5.3%), and
China (5%) (UN Trade and Development
(UNCTAD)). In 2024-25, professional and
management consulting services emerged
as a key sub-sector of services, contributing
nearly 20% of India’s total services exports
(RBI Data on India’s Invisibles).
Business services, including professional
services, form the backbone of the services
value chain. They serve as essential inputs
across all sectors, including manufacturing,
construction, agriculture and the broader
services sectors. Professional services,
particularly, have been recognised as one
of the key drivers reshaping India’s services
landscape (Economic Survey 2024-25, 243).
In 2023, it constituted 19.7% of India’s total
services exports, achieving a compound
annual growth rate (CAGR) of 18% (FY15-
FY25). On the import side, professional
services accounted for 10% of India’s total
services imports, growing at a CAGR of 8%
(FY15-FY25). Thus, professional services
have immense potential to enhance India’s
share in global services trade (RBI Data).
Professional services are high-value,
knowledge-intensive services, such as, legal
services, accounting and auditing services,
architectural services, engineering services,
and health services. These services have a
long history of evolution spanning the pre-
colonial, colonial and post-colonial eras,
shaped by civilizational knowledge, colonial
restructuring, and post-independence
regulatory state-building.
1.2 Evolution of Professional
Services
In ancient India, foundational texts such
as the Dharmas´a¯stra and Arthashastra
among others, codified knowledge systems
of skilled professions that resonate with
the modern conception of professional
services. They prescribed standards of
practice, qualifications of professionals
and ethical norms for practitioners. For
instance, physicians in ancient India
practiced one of the oldest systems of
medicine, guided by the Caraka Samhita
and Sushruta Samhita, composed roughly
around the first millennium BCE. The Caraka
Saṃhita¯ elaborates general principles of
medical science and conduct of medical
practitioners, while Suśruta Saṃhitā details
surgical instruments, practice of surgery
and procedures (Chattopadhyaya, 1977).
Similarly, law was guided by Dharmaśāstra
texts such as the Manusmriti  and Yajnavalkya
Smriti, which outline legal procedures,
qualifications for judicial roles, and ethical
standards for practitioners (Kane, 1946).
The Shilpa Shastra  and  Vastu Shastra,
guided architecture and engineering (Kane
CHAPTER OUTLINE
1.1 Introduction
1.2 Evolution in
Professional Services
1.3 Trends in Professional
Services
1.4 Global Services Trade
Architecture

India’s Services Sector: Insights on Regulatory Regime in Professional Services5
1946; Thaplyal, 2001) and the Arthashastra,
dictated the conduct of commerce
(Shamasastry, 1951). Complementing
these texts, ancient India also had guilds
or śreṇīs, which functioned as professional
bodies. Many of them worked under royal
patronage, particularly during the Mauryan
and Gupta periods, thus fostering a culture
of formalisation well before the emergence
of modern regulatory institutions (Thaplyal,
2001).
With the advent of colonial rule, these
indigenous systems gradually declined,
giving way to institutions modelled on
western standards. The British East India
Company (EIC) and later the Crown,
both introduced regulatory frameworks
primarily to favour western practitioners
over Indians. Introduction of professional
bodies, licensing systems and educational
institutions modelled on then prevailing
western standards was intended to exclude
indigenous systems and marginalise Indians.
While colonial influence reshaped nearly
every discipline, its impact was particularly
profound in law and medicine.
.Regulation of medicine in India began with
the advent of British surgeons under the EIC.
Over time, the British established medical
colleges, introduced licentiate programs and
set up professional bodies for centralized
oversight, marginalizing indigenous systems
like Ayurveda and Unani and excluding
native Indian practitioners. They introduced
the Native Medical Institution in 1822 and
English-medium colleges like the Calcutta
Medical College in 1835. The Indian Medical
Services were set up in 1897 for centralized
oversight of health services. Formal
regulation intensified from 20th century
onwards with the introduction of the Indian
Medical Degrees Act, 1916, for standardized
degrees and the Indian Medical Council Act,
1933, establishing the Medical Council of
India (MCI) as a central body for governance.
In Law, the British replaced indigenous justice
systems and customary law with the common
law framework. They overhauled the judicial
systems with western-style courts such as
the Mayor’s court in 1726, the Supreme Court
of Judicature in 1773, and the High Courts in
1862 (Fawcett, 1934). This new court system
also gave rise to legal practitioners such as
advocates, attorneys, and barristers as they
existed in England. The Legal Practitioners
Act, 1879, a precursor to the Advocates Act,
1961, formed the basis of governance of legal
practitioners (History of Legal Profession,
BCI). The British also undertook extensive
codification of Indian statutes, resulting
in civil laws such as the Indian Contract
Act, 1872, the Indian Evidence Act, 1872
(repealed), the Transfer of Property Act, 1882
and criminal codes such as the Indian Penal
Code, 1860 (repealed).
By 1947, India’s modern professional services
had been decisively shaped by colonial
legacy. India inherited a blend of colonial
institutional frameworks and indigenous
traditions. The post-independence period has
been marked by efforts to recalibrate these
systems to support national development
and modernisation.
In 1955, the government of India established
the first Law Commission with the aim of
revising and updating the inherited laws.
The Commission examined a wide range of
statutes, including British statutes applicable
to India, Partnership Act, 1932, Income Tax
Act, 1922, Indian Contract Act, 1872 and
many others. Since then, twenty-three
law commissions have been constituted,
most recent on September 1, 2024, each
tasked with reforming the field of law in
India. Additionally, India also enacted the
Advocates Act, 1961 for governance of
Advocates and establishment of Bar Council
of India as the apex governing body.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 6
India also constituted the Bhore Committee
(Health Survey and Development Committee)
to study India’s healthcare systems. In its 1946
report, this committee made foundational
recommendations such as an integrated
health system, primary health centres in rural
areas, a three-tier healthcare structure, and
reforms in medical education (Report of the
Health Survey and Development Committee,
1946). Subsequent years saw the formation
of many commissions such as the Mudaliar
Committee (Health Survey and Planning
Committee) of 1959, the Jain Committee of
1966 and Jungalwalla Committee of 1967
to review various areas of the healthcare
system. Over time, India also adopted key
policy frameworks, including the National
Health Policies of 1983 and 2002, and the
National Health Mission of 2013, aimed
at strengthening healthcare delivery and
improving public health outcomes (Raj,
2024). Newer legislations, such as the Indian
Nursing Council Act, 1947, the Indian Medical
Council Act, 1956, and the Indian Medical
Council (Professional Conduct, Etiquette,
and Ethics) Regulations, 2002, were enacted
to govern the qualifications and practice of
medical professionals. The Medical Council of
India (since replaced by the National Medical
Commission) was established as the apex
regulatory authority overseeing medical
education and professional conduct.
1.3 Trends in Professional
Services in India
Professional services in India have
continuously evolved, but initially had a
limited contribution towards the services
sector. In fact, India's economy in the post-
independence era was primarily agrarian
(Mukherjee, 2013). However, the services
sector experienced a steady growth,
particularly from the 1980s, which further
accelerated following the economic reforms
of 1991. This services sector boom of 1991
was dominated by communications services,
driven by domestic demand, and business
services, driven by exports (Nagaraj, 2008).
Unlike many South Asian and emerging
economies, India’s economic trajectory
transitioned almost directly from agriculture-
led to service-driven, bypassing a dominant
industrial phase (Ansari, 1995). Today, in
both developing and developed economies,
the services sector, including professional
services, contributes a larger share to GDP.
Notably, services value-added accounts for
about 62% of the global GDP (Economic
Survey 2024-25).
In FY24, the services sector contributed 55%
to India’s GDP and approximately 55% of
India’s Gross Value Added (GVA), recording a
CAGR of around 7% from 2011–12 to 2023–24.
This sector also accounts for almost 30% of
the total employment and remains the top
recipient of total Foreign Direct Investment
(FDI) (Economic Survey, 2024-25). Thus,
professional services can be viewed as a
central pillar in India’s services-led growth.
The information and communication
technologies (ICT) revolution further
positively impacted the services sector
growth by removing the burden of physical
proximity. It has transformed many contact-
intensive services, previously deemed “non-
tradable”, into tradable services (Digital Trade
for Development, 2023). Within services,
professional services have particularly
benefited from these ICT advancements,
as these services have become storable,
codifiable and transferable. Thus, professional
services have been recognised as a high-skilled
offshorable service that is more productive
than low-skilled services, in emerging
economies. However, professional services
remain one of the most protected industries
in many emerging and advanced economies.
Consequently, policy measures to promote
trade in professional services could yield
significant economic benefits for emerging
economies (Nayyar and Davies, 2023).

India’s Services Sector: Insights on Regulatory Regime in Professional Services7
1.4 Global Services Trade
Architecture
To enhance the economic contribution of
professional services, it is also essential to
understand the international services trade
architecture that supports it. Services were
not included in multilateral trade frameworks
until the 1990s. Prior to this, trade in services
was governed through bilateral and regional
agreements with limited scope, typically
focusing on specific services (Marchetti
and Mavroidis, 2011). For example, the
United States and Israel signed a Free Trade
Agreement (FTA) as early as 1985, and United
States and Canada entered into the Canada-
United States Free Trade Agreement in 1988.
In the 1970s, the United States spearheaded an
initiative to establish a multilateral framework
for trade in services. This led to the launch of
negotiations known as the Uruguay Round in
1986, to address new areas of trade, particularly,
services. Many leading developing countries,
including India, initially opposed the inclusion
of services in the negotiations due to concerns
about losing regulatory oversight over key
services sectors (Marchetti and Mavroidis, 2011).
These negotiations, ultimately, culminated
in the Marrakesh Agreement of 1994, which
established the World Trade Organization
(WTO) as a permanent international body, and
finalized the General Agreement on Trade in
Services (GATS).
GATS came into force on January 1, 1995,
as part of the WTO framework, as the first
multilateral framework for trade in services.
Notably, GATS also does not define services,
but merely lays down four modes through
which services may be traded. They are: i)
Mode 1 or cross-border supply i.e. delivery
of services from one country to another
without the physical movement of either the
service provider or the consumer; ii) Mode
2 or consumption abroad i.e. movement of
consumers to another country to receive a
service, as in the case of medical tourism;
iii) Mode 3 or commercial presence i.e.
establishment of a business operation, such
as a branch office, subsidiary etc. in a foreign
country; and iv) Mode 4 or presence of natural
persons i.e. temporary movement of persons
from one country to another country to supply
services without seeking employment or
permanent residency. Further, services were
classified into 12 broad categories under the
WTO’s Services Sectoral Classification List
(MTN.GNS/W/120), which in turn facilitated
structured government commitments under
the four modes of supply. Figure 1 illustrates
the supply of services through the four
modes of supply.
Figure 1. Illustrations of the four modes of supply
Indian Ar chitect electr onically sends
design t o Bali
A patient fr om Nigeria tr avels to India f or
medical tr eatment
A firm in UK es tablishes a br anch offic e in
India
Mode 1
Mode 2
Mode 3
Mode 4
An Indian sent abr oad b y a MNC as an Intr a
Corpor ate Transferee

India’s Services Sector: Insights on Regulatory Regime in Professional Services 8
Article VI of GATS establishes key principles to
ensure domestic regulations governing trade
in services foster fairness and transparency
without imposing unnecessary barriers to
services trade. This article establishes the
foundation for regulating disciplines that
specifically impact professional services,
promoting fair and transparent regulation
(R. Chanda, 2002). Guided by this mandate,
WTO Members established the Working Party
on Professional Services (WPPS) in 1995 to
develop disciplines for professional services,
starting with accountancy. This resulted
in the Disciplines on Domestic Regulation
in the Accountancy Sector and Guidelines
for Mutual Recognition Agreements or
Arrangements in the Accountancy Sector,
in 1998, designed to enhance transparency
and fairness in accountancy services. These
disciplines were intended for integration
into GATS upon conclusion of the Doha
Development Round, launched in November
2001. However, they remain non-binding as
the Doha Round is yet to conclude. In 1999
the WPPS was replaced with the Working
Party on Domestic Regulation (WPDR),
with a broader mandate to develop general
disciplines for all services sectors under
GATS. However, negotiations under the
WPDR framework have also not achieved
conclusive results.
To address the stalled progress, the Joint
Initiative on Services Domestic Regulation
(JI-SDR) was launched by 59 WTO members,
in 2017. This plurilateral initiative sought
to build on the WPDR’s efforts and to
finalize disciplines ensuring transparency,
predictability, and efficiency in service
provider authorization. By December 2021,
JI-SDR had concluded the Reference Paper
on Services Domestic Regulation, covering
licensing, qualifications, and technical
standards with a novel provision for gender
non-discrimination in authorizations and the
same was adopted by 67 WTO members. As
of August 2026, the disciplines have entered
into force for 56 WTO members. Currently,
a total of 72 economies are committed to
implementing the JI-SDR. However, India is
not a signatory to this initiative. Nevertheless,
these disciplines will be applied on a “most-
favoured nation” basis, meaning they will
benefit all WTO members, including India.
Domestic regulations, thus, play a vital role in
facilitating both domestic and international
trade in services. In particular, domestic
regulations governing professional services

India’s Services Sector: Insights on Regulatory Regime in Professional Services9
are increasingly gaining significance in
the context of India’s ongoing Free Trade
Agreement (FTA) negotiations.
Given the growing importance of the
professional services sector in India, not only
in trade but also in employment generation
and contribution to GVA, it is essential to
examine the domestic regulatory framework
that impacts this sector. Excessively
restrictive regulations can create significant
barriers for both domestic and foreign service
providers. These regulations, which may stem
from government policies or professional
bodies, often include restrictions on foreign
participation, nationality or residency
requirements and licensing conditions,
among others (Nguyen-Hong, 2000). This
report, thus, attempts to present a factual
assessment of India’s regulatory regime in
professional services with an objective to
identify bottlenecks and highlight avenues
for enhancing their economic contribution.
For this purpose, this report follows the
professional services classification based on
the WTO’s Services Sectoral Classification
List (MTN.GNS/W/120).
Accordingly, this report is divided into the
following chapters: Chapter 2 presents a
factual overview of the horizontal or cross-
sectoral laws impacting India’s services
sector, along with sector-specific laws and
regulations governing the provision of
professional services; Chapter 3 outlines the
stakeholder consultations conducted for this
1 Revealed Comparative Advantage (RCA) measures a country’s relative ability to export specific goods or services
compared to the global average, with RCA values above 1 indicating sectors where India holds a comparative advan-
tage. RCA = India’s share of exports of professional, management & consulting services/World’s share of exports of
professional, management & consulting services. As per the author’s calculation from the UNCTAD database, India’s
RCA in professional and management consulting services has increased from 0.95 in 2005 to 3.0 in 2024, thereby
indicating India’s competitive edge in professional & management consulting services.
report; Chapter 4 highlights key regulatory
gaps identified during the said consultations;
and Chapter 5 offers sectoral insights drawn
from the consultation process and provides
a four-pronged strategy to strengthen
India’s professional services ecosystem.
Additionally, this report consists of two
annexures: Annexure I presents country
positions in select jurisdictions in professional
services. Annexure II lists stakeholders who
participated.
As India approaches its demographic peak,
professional services offer a vital pathway for
high-skilled employment, entrepreneurship,
and innovation, strengthening India’s
comparative advantage
1
in the professional
services trade. This report encapsulates a
factual and structural analysis of professional
services aiming to serve the following
purposes: first, highlight the existing legal
and regulatory framework to support the
establishment of business by both domestic
and foreign professional service suppliers;
second, identify regulatory gaps and
challenges as highlighted by stakeholders,
and thereby enable efforts to enhance the
competence and mobility of professionals;
and third, to support India’s multilateral and
bilateral trade negotiations. By fostering
a well-regulated, globally competitive
ecosystem, professional services can drive
efficiency, boost exports, and contribute
significantly to realizing the Vision of a Viksit
Bharat by 2047.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 10

India’s Services Sector: Insights on Regulatory Regime in Professional Services112
Regulatory
Landscape

India’s Services Sector: Insights on Regulatory Regime in Professional Services 12
2.1 Introduction
The professional services sector in India is
regulated by a set of horizontal/cross-sectoral
laws (hereinafter referred to as “horizontal
laws”) and sector-specific laws. Sector-
specific laws govern individual professions
such as law, accounting and auditing,
architecture, and healthcare. They establish
eligibility criteria for professionals, specify
the permitted legal forms of establishment
in each sector, and define other conditions
for the supply of services. Accordingly, they
determine who can practice a profession,
under what type of entity, and subject to
what conditions.
Horizontal laws, by contrast, apply across
all sectors, including professional services
sectors. These laws encompass a wide range
of regulations, including those related to
taxation, consumer protection, competition,
labour and employment, technology, data
protection, environmental clearance, as
well as regulations governing the forms
of establishment, investment, and trade in
services. They play a crucial role in shaping
the business ecosystem of the professional
services sectors, including the establishment,
operation, and expansion of businesses, both
domestically and internationally.
While horizontal laws affect different aspects
of the supply of professional services in
India, Section 2.2 of this chapter solely
focuses on horizontal laws and regulations
that govern the establishment of entities.
These laws govern the permissible forms
of establishment, investment, and trade,
thereby shaping ownership structures,
liability, governance, access to capital, and
compliance obligations. For domestic services
suppliers, they influence competitiveness
and integration with the global value chains,
while for foreign firms, they establish rules
for market access, cross-border trade, and
investment. In effect, these laws serve as the
gateway for professional service suppliers
to participate in India’s economy as well
as in the international trade of professional
services.
Against this backdrop, Section 2.3 of
this chapter analyses the sector-specific
frameworks that regulate the practice of
professionals in India. It presents a sector-
by-sector analysis of professional services,
identified based on the WTO’s services
sectoral classification list (MTN.GNS/W/120).
The analysis is structured around three
key dimensions: (1) laws and regulations
that govern the practice of professionals;
(2) competencies of professionals, which
include educational qualification and
licensing requirements; and (3) restrictions
on rendering professional services, including
legal forms of establishment, advertisement,
fee restrictions, etc.
Examining sector-specific regulatory
frameworks through these three dimensions
is crucial, as together they define both the
scope and the limits of professional service
delivery in India. These laws and regulations
establish the legal framework within
which professionals operate. Competency
requirements, such as qualifications and
licensing, determine the eligibility to practice
and help ensure the quality and credibility
of services. Restrictions on the rendering of
services, including limitations on permitted
forms of establishments, advertising, or fees, 2
Regulatory Landscape
CHAPTER OUTLINE
2.1 Introduction
2.2 Horizontal Laws
Affecting Establishment
2.3 Sector-specific
Regulatory Framework

India’s Services Sector: Insights on Regulatory Regime in Professional Services13
directly affect how professionals can structure
and grow their practices. Additionally, RBI’s
data on exports and imports from 2014-15
to 2024-25 have also been considered to
understand the growth trends in these fields.
However, this data primarily captures Mode
1, Mode 2, and certain Mode 4 components
(Mattoo, Stern and Zanini, 2007).
Thus, the examination of horizontal and
sector-specific laws through the
aforementioned three dimensions provides
a comprehensive view of the regulatory
environment in the professional services
sub-sector. It traces the life cycle of service
delivery, from eligibility of individuals and
entities to practice, to the actual supply of
service. In doing so, this chapter highlights
the current state of play in professional
services and how India’s regulatory regime in
professional services supports both domestic
and international participation.
2.2 Horizontal Laws Affecting
Establishment
This section focuses on the key horizontal or
cross-sectoral laws that affect professional
service suppliers in establishing their
businesses in India. It includes laws governing
the legal forms of establishment, as well
as laws and regulations under the Foreign
Exchange Management Act (FEMA), and
RBI master directions that lay down the
conditions for foreign and domestic firms
to establish and maintain their presence in
India. These laws and regulations determine
the procedure for establishing companies,
partnerships, limited liability partnerships,
and sole proprietorships, as well as scrutinize
the cross-border movement of capital and
regulate the supply of services.
2.2.1 Legal Framework Affecting
Commercial Presence
The primary focus of this section is on
the various types of legal structures
that businesses can adopt to establish a
commercial presence in India. Although
there are restrictions on the permitted forms
of establishment in certain professional
services sectors (addressed in Section 2.3
of this chapter for each sector), a business
entity can typically choose one of four forms
of establishment: (1) Incorporated Company,
(2) Limited Liability Partnership (LLP), (3)
Partnership Firm, or (4) Sole Proprietorship.
The specific types of entities permitted within
each professional services sector covered in
this report are discussed in Section 2.3 of this
chapter. The following paragraphs provide a
brief overview of the legal and regulatory
framework governing each of these forms of
establishment.
(i) Incorporated Company
Under the Companies Act, 2013 (TCA, 2013),
businesses can establish a commercial
presence in India by incorporating a
company, typically as a private limited
company or public limited company, either
as a wholly owned subsidiary or through
a joint venture with an Indian partner. This
Act, enforced by the Ministry of Corporate
Affairs (MCA), provides a comprehensive
framework for the incorporation, regulation,
and governance of companies in India.
The incorporation process is governed
by sections 3 to 22 of TCA, 2013. Section
7 of the Act outlines the procedure for
incorporating a company and the manner
in which the filing process for incorporation
is to be conducted. Furthermore, sections
379 to 393 of the Act outline the rules that
a foreign company, incorporated outside
India but having a place of business
in India, must follow. Additionally, the
Companies (Incorporation) Rules, 2014,
and the Companies (Registration of
Foreign Companies) Rules, 2014, lay down
detailed procedures for the incorporation
and registration of foreign companies,
respectively.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 14
(ii) Limited Liability Partnership
The Limited Liability Partnership Act,
2008 and the Limited Liability Partnership
Rules, 2009 (LLP Rules, 2009), govern
the incorporation of limited liability
partnerships (LLPs) in India. An LLP
functions as a body corporate distinct from
its partners and has perpetual succession
i.e. any change in the partners of the LLP
shall not affect the existence, rights or
liabilities of it. Under sections 6 and 7 of
the Act, an LLP must have at least two
partners and two designated partners.
While partners in an LLP contribute capital
and share profits/losses, forming part
of the ownership structure, designated
partners are specifically appointed to
fulfill statutory and regulatory obligations
of the LLP. The designated partners must
be individuals, and at least one of them
must be a resident of India. Sections 11 to
21 of the Act, along with rules 11 to 20 of
the LLP Rules, 2009, lay down the step-by-
step process for incorporating an LLP. This
includes filing incorporation documents,
securing a name reservation for the LLP,
registering the entity, and obtaining a
Limited Liability Partnership Identification
Number (LLPIN). These requirements apply
whether the partners are Indian nationals
or foreign entities. If an LLP incorporated
outside India wishes to be incorporated
in India, it must comply with section 59
of the Act and rule 34 of the LLP Rules,
2009. These provisions prescribe separate
procedures for foreign LLPs incorporated in
(i) Commonwealth countries, (ii) countries
that are parties to the Hague Apostille
Convention, 1961, and (iii) countries that fall
under neither category.
(iii) Partnership Firm
The Indian Partnership Act, 1932, is the
primary legislation governing partnership
firms in India. Section 4 of the Act defines
“partnership” as the relation between
persons who have agreed to share the
profits of a business carried on by all or
any of them acting for all. According to
Section 5 of the Act, a partnership requires
a minimum of two partners and is formed
via a contract. Section 6 further clarifies
that the existence of a partnership or a lack
of it is determined based on all relevant
facts taken together. The Act outlines
the nature of partnerships and provides
a framework for the registration and
dissolution of partnership firms. It outlines
the duties, rights, and liabilities of partners
in partnership firms. Section 11 states that
the mutual rights and duties of the partners
in the firms may be determined through
contract, whether expressed or implied.
Section 25 states that every partner is
liable, jointly with all the other partners and
also severally, for all acts of the firm done
while he is a partner. Further, as per section
26, the firm becomes liable for the wrongful
acts or omissions of a partner acting in the
ordinary course of business. Chapter V of
the Act covers details ranging from the
introduction of a partner to the retirement,
expulsion, and insolvency of a partner.
(iv) Sole Proprietorship
A sole proprietorship represents the
simplest form of business structure in
India, where the sole proprietor owns,
manages, and controls the business and
assumes unlimited personal liability for its
obligations. Depending on the nature of
professional services offered, the proprietor
must obtain sector-specific licenses or
registrations. For example, a doctor or
chartered accountant who sets up a
practice may require registration under the
Shops and Establishments Act applicable in
their state. Further, any person establishing
a clinic must mandatorily register their
clinic under the Clinical Establishment
(Registration and Regulation) Act, 2010. As

India’s Services Sector: Insights on Regulatory Regime in Professional Services15
far as the tax liability of sole proprietorship
is concerned, since the law does not
distinguish between the business and the
individual, the proprietor’s income from the
business is taxed as personal income under
the Income Tax Act, 2025.
Box 1. Registration under the Shops and Establishments Act
While an entity rendering professional services may adopt any of the aforementioned legal
structures to establish a commercial presence, these entities may require a registration under
the applicable state-specific Shops and Establishments Act. This registration provides official
recognition of the business and is typically required to open a current bank account, obtain
regulatory licenses, and comply with local labour laws. While originally intended for shops
and retail businesses, most state laws, such as the Delhi Shops and Establishments Act, 1954,
the Karnataka Shops and Commercial Establishments Act, 1961, and the Maharashtra Shops
and Establishments (Regulation of Employment and Conditions of Service) Act, 2017, define
“establishment” broadly to include professional service establishments. These laws govern
employment conditions, such as working hours, leave entitlements, holidays, and employment
conditions, making it a key compliance requirement for professional service providers with
office-based operations. Additionally, professional service suppliers must also register under the
relevant laws and regulations governing their specific profession, where applicable.
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2.2.2 Other Laws and Regulations
This section examines laws and regulations
that affect the supply of services, including
professional services, by overseas service
suppliers. The Foreign Exchange Management
Act, 1999 (FEMA, 1999), along with its
rules and regulations, and the RBI’s Master
Directions, are the primary laws governing
these aspects. It regulates the conditions
for foreign firms to enter and operate in the
Indian market, with respect to both capital
account transactions, that is, transaction
which alters the assets or liabilities, including
contingent liabilities, outside India of persons
resident in India or assets or liabilities in India

India’s Services Sector: Insights on Regulatory Regime in Professional Services 16
of persons resident outside India (FEMA 1999,
sec. 2.e), and current account transactions,
that cover payments linked to foreign trade,
other current business, services, income from
investment, remittances, and consumption
abroad (FEMA 1999, sec. 2.j).
A defining feature of FEMA is its
extraterritorial applicability. It extends to all
branches, offices, and agencies outside India
that are owned or controlled by any individual
or entity residing in India, and it holds them
accountable for violations committed abroad
if they fall within the scope of the Act (FEMA
1999, sec. 1.3).
Notably, sections 46 and 47 empower
the central government and the RBI to
issue detailed rules and regulations under
FEMA, 1999. In this regard, this section also
highlights specific rules and regulations that
may have implications on the professional
services ecosystem. The Foreign Exchange
Management (Current Account Transactions)
Rules, 2000, for instance, prescribe the
foreign exchange limit for individuals and
for persons other than individuals for
education and employment abroad, medical
treatment, and consultancy services, among
others (Schedule III). The Foreign Exchange
Management (Non-debt Instruments) Rules,
2019, set conditions for investing in non-
debt instruments, including the acquisition
and transfer of immovable property for
companies and limited liability partnerships.
Additionally, Schedule I of the Rules and
the Consolidated FDI Policy Circular, 2020,
specifies the FDI cap through the automatic
and government routes for each sector;
however, the FDI cap for the professional
services sector is not specified.
The Foreign Exchange Management
(Overseas Investment) Rules, 2022 (OI
Rules, 2022), and the Foreign Exchange
Management (Overseas Investment)
Regulations, 2022 along with the RBI Master
Direction on Overseas Investments 2024,
outline the procedures for making overseas
investments by a person resident in India
(OI Rules 2022, Schedules I to V) and the
conditions for the acquisition or transfer of
immovable property by a person resident
in India and Indian entities with an overseas
office. Further, the Foreign Exchange
Management (Establishment in India of a
Branch or a Liaison Office or a Project Office
or any Other Place of Business) Regulations,
2016, mandate conditions for persons
(business entities) resident outside India to
open a branch office, liaison office, project
office, or any other place of business in
India, subject to prior approval from the RBI.
Regulation 4(b) and Annex B, Schedules I and
II, outline the permitted activities for such
offices, including the provision of rendering
professional or consultancy services by a
branch office.
Additionally, with the powers given to
the RBI under section 11 of FEMA, 1999, it
issues Master Directions to regulate foreign
exchange, investments, and trade in services.
These Master Directions compile all relevant
rules and regulatory instructions issued
by the RBI under various laws, including
those related to foreign exchange and
investment. For each subject, the RBI issues
a single Master Direction that consolidates all
applicable guidelines and instruction.
2.3 Sector-specific Regulatory
Framework in Professional
Services
India’s regulatory framework for
professional services is diverse and sector-
specific. Professions such as medicine,
law, accounting, and auditing (regulated
sectors) are governed by well-defined legal
and institutional frameworks. In contrast,
professions such as engineering, urban
planning, and landscape architecture are
lightly regulated or lack formal oversight.

India’s Services Sector: Insights on Regulatory Regime in Professional Services17
In regulated sectors, professionals
experience various entry and operational
conditions, including nationality or residency
requirements, educational qualifications
and licenses, restrictions on permitted legal
forms of establishment, and recognition of
foreign qualifications. However, professionals
in unregulated sectors may operate without
conditions such as licensing, as their practice
is not governed by a specific statutory
framework.
Foreign-trained professionals may practice
in India, on satisfying certain sector-specific
conditions, including recognition of their
qualifications by the relevant authority,
completion of a bridge course, clearing a
qualifying examination, and registering with
the appropriate national or state authority.
These requirements are also sector-specific
in nature.
The regulatory regime in professional
services can be discriminatory or non-
discriminatory in nature. In regulated sectors,
laws and regulations governing market
access and national treatment may apply
uniformly to Indian citizens and foreigners,
or they may differ depending on the
category of professional. For example, the
process of recognition of qualification varies
across sectors for Indian nationals, Overseas
Citizens of India (OCI), Persons of Indian
Origin (PIO), and foreign nationals. The
commitments India undertakes in its FTAs
also provide useful insight into its regulatory
regime. However, these commitments need
not be binding on the extant regulatory
regime. Accordingly, this section also
examines India’s FTA commitments across
professional services sub-sectors to assess
how they reflect the regulatory regime.
2
From the perspective of a foreign service
supplier, both discriminatory and non-
2 For the purpose of this chapter, the authors have examined the schedules of commitments under GATS and India’s
FTAs. The analysis covers the following FTAs: (1) India–Singapore, (2) India–Korea, (3) India–Malaysia, (4) India–Ja-
pan, (5) India–Mauritius, (6) India–UAE, (7) India–Australia, (8) India–EFTA, and (9) India–United Kingdom.
discriminatory measures may restrict the
supply of services. In this regard, the OECD
Services Trade Restrictiveness Index (STRI)
provides a comprehensive tool for evaluating
regulatory barriers across 22 major sectors
in 51 countries. It measures restrictiveness
for foreign services suppliers in five key
categories: (1) restrictions on foreign
entry, (2) restrictions on the movement of
people, (3) other discriminatory measures
such as subsidies or public procurement
restrictions, (4) barriers to competition, and
(5) regulatory transparency. Each category
includes specific measures, scored on a scale
from 0 to 1, with scores closer to 1 indicating
higher restrictiveness.
However, the OECD STRI is not without its
shortcomings. Several factual inconsistencies,
along with conceptual and methodological
flaws, limit its overall accuracy. While the
index classifies regulatory barriers into
five broad policy areas, these categories
do not capture the full range of possible
restrictions, nor do they account for sector-
specific liberalisation within a given category.
Moreover, the STRI adopts a largely binary
approach to evaluation. For instance,
whether a country requires draft laws to be
published in advance with a comment period
is assessed only through a yes/no response.
Broader practices or policy frameworks that
may ensure transparency in most cases are
disregarded. As a result, the final scores
may fail to accurately reflect the real level of
restrictiveness or openness in an economy
(Gupta et al. 2020, 11).
For professional services, the coverage of
the STRI is even more limited, extending only
to accounting, architecture, engineering,
and legal services. Within these professions,
India’s regulatory environment is assessed
as highly restrictive for legal services
(0.865), followed by accounting (0.762) and

India’s Services Sector: Insights on Regulatory Regime in Professional Services 18
architecture (0.537). By contrast, engineering
services register a much lower score of 0.155,
pointing to greater openness in the sector.
Figure 3 provides an overview of the overall
restrictiveness levels across these sub-
sectors vis-à-vis the top five most restrictive
countries and the bottom five least restrictive
countries, and India’s ranking and score for
the sub-sectors covered by the OECD STRI.
Against this backdrop, the subsequent
3 The MTN.GNS/W/120, or the W/120 list by the WTO, classifies the services sector into 12 broad categories.
Professional Services comes under the head of Business Services that comprises of the following: (1.A.a) Legal
services, (1.A.b) Accounting, auditing and bookkeeping services, (1.A.c) Taxation services, (1.A.d) Architectural
services, (1.A.e) Engineering services, (1.A.f) Integrated engineering services, (1.A.g) Urban planning and landscape
architectural services, (1.A.h) Medical and dental services, (1.A.i) Veterinary services, (1.A.j) Services provided by
midwives, nurses, physiotherapists and para-medical personnel. For the purpose of this study, the authors have
grouped professional services sub-sectors to capture maximum overlaps.
sections factually analyze India’s regulatory
regime across the professional services sub-
sector. While the WTO’s Services Sectoral
classification (W/120 list) categorizes
professional services under various heads,
3

the subsequent sections broadly analyse
the following sub-sectors: (i) Legal services,
(ii) Accounting, auditing and bookkeeping
services, (iii) Architectural services, (iv)
Engineering services, (v) Healthcare and
allied healthcare services. Le Le
THREE KEY DIMENSIONS TO ANALYSE PROFESSIONAL
SERVICES SUB-SECTORS
Laws and regulations
that govern professional
practice
Analyzes whether a legal
framework exists that outlines
the scope of practice
Competencies of
professionals
Highlights the eligibility
of professionals to supply
services - educational
qualification + licenşureLe
Sectors:
Legal; Accounting, Auditing and Bookkeeping;
Architecture; Engineering; Healthcare and Allied healthcare.
Restrictions on
supply of services
Conditions that limit or
restrict the supply of
services - restrictions on
advertisement, fee, forms
of establishment

India’s Services Sector: Insights on Regulatory Regime in Professional Services19
Figure 3. Country-wise Comparison of OECD STRIAccounting Services Architecture Services Legal Services Engineering
Services India’s Ranking
out of 51
countries pfl q
9fl i -fl fl q
4 v i 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
0
Korea
Thailand
Philippines
India
China
1.000
1.000
0.795
0.762
0.682 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
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Slovak Republic
Lithuania
Netherlands
United States
Germany
0.146
0.156
0.158
0.170
0.172 ) ! L 0
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0
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0
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8
1
.
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Philippines
India
Thailand
Slovak Republic
Russia
1.000
0.537
0.461
0.392
0.372 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
0
Chile
Denmark
Czechia
Spain
China
0.143
0.147
0.147
0.148
0.151 ) ! L 0
!L 0 .B 0BO ! +L 0
!L 0 .B 0BO ! G '
1 + . ! 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
0
Philippines
Slovak Republic
Italy
Slovenia
Russia
0.659
0.469
0.386
0.366
0.354 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
0
France
Latvia
Lithuania
Denmark
Australia
0.129
0.133
0.141
0.142
0.144 ) ! L 0
!L 0 .B 0BO ! +L 0
!L 0 .B 0BO ! G '
1 + . ! 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
0
Philippines
Poland
India
Indonesia
Hungary
1.000
1.000
0.865
0.865
0.707 0
.
0
0
.
2
0
.
4
0
.
6
0
.
8
1
.
0
Finland
Colombia
Portugal
Peru
Sweden
0.127
0.129
0.134
0.144
0.147 +L 0
!L 0 .B 0BO ! ) ! L 0
!L 0 .B 0BO ! G '
1 + . ! 1 ! 0 ! .
Note: Based on OECD STRI rankings among these 51 countries, India ranked 2nd in Architectural Services, 3rd in Legal Services, and 4th in Accounting Services, indicating
high regulatory restrictiveness in these sectors. In contrast, it ranked 38th in Engineering Services, reflecting a more liberal regulatory environment in the sub-sector. In the
OECD STRI, a higher rank corresponds to greater restrictiveness, while a lower rank indicates fewer barriers to trade in services. In the Legal and Accounting Services Sector,
India imposes maximum restrictions on foreign entry, including a prohibition on the incorporation of companies and a ban on commercial association with other professionals.
Source: OECD (accessed on September 2025)

India’s Services Sector: Insights on Regulatory Regime in Professional Services 20
2.4 Legal Services
In India, the legal profession is traditionally
considered as a noble profession rather than
a commercial activity (BCI Notification, F.
No. BCI:D: 3335/2025), which has inspired
the sector to remain largely insulated from
foreign competition and the regulations to
be shaped accordingly. While this approach
upholds the integrity of the profession, it
has also limited the flow of global talent
and investment into the Indian legal market.
At the same time, Indian lawyers often
face considerable barriers when seeking to
practice abroad, particularly in jurisdictions
like the UK and the USA, owing to licensing
requirements and immigration hurdles, raising
concerns about fairness and reciprocity in
international legal services (Papa & Wilkins,
2012).
Easing restrictions presents an opportunity
to boost trade in legal services. The RBI’s
data on exports and imports in Figure
4 shows that exports rose steadily from
US$852 million in 2014-15 to US$1,279 million
in 2024-25, while imports increased from
US$326 million to US$750 million in the same
period, albeit with greater volatility. Despite
the growth in exports and fluctuations in
imports, the sector’s contribution to India’s
overall professional services trade remains
modest, pointing to the untapped potential
that may be leveraged.
Figure 4. Trade in Legal Services
Source: RBI data on invisibles
In recent years, the Bar Council of India
(BCI) has stated that the time has come to
reconsider the issue of opening India’s legal
sector to foreign lawyers in specific areas,
such as foreign law practice, international
legal issues in non-litigious matters, and
international arbitration (Bar Council of India
Rules for Registration and Regulation of
Foreign Lawyers and Foreign Law Firms in
India, 2022) (amended and notified in 2025).
BCI emphasized that Indian lawyers possess
proficiency comparable to global standards
and would not face disadvantages if foreign
lawyers were allowed to practice under
a restricted, well-regulated framework
based on reciprocity. Such reforms could
benefit both Indian and foreign lawyers,
attract Foreign Direct Investment (FDI), and

India’s Services Sector: Insights on Regulatory Regime in Professional Services21
establish India as a hub for international
commercial arbitration. A closer examination
of the domestic regulatory framework
provides further insights into the sector’s
current regulatory landscape.
2.4.1 Legal and Regulatory
Framework for Professionals
Rendering Legal Services
The Advocates Act, 1961, governs the legal
profession in India, wherein it recognises
a single category of legal practitioners, i.e.
Advocates. Under section 29 of the Act,
anyone intending to practice law in India must
qualify and enroll as an Advocate. The Act
defines an Advocate as an “advocate entered
in any roll under the provisions of this Act”.
It also provides definitions for related terms:
(i) “Law graduate” means a person who has
obtained a bachelor’s degree in law from any
University established by law in India; (ii)
“Legal practitioner” means an advocate or
vakil of any High Court, a pleader, mukhtar
or revenue agent (The Advocates Act, 1961,
section 2(1)). As per section 33 of the Act,
no person other than enrolled Advocates
are permitted to practice in a court of law in
India.
To be eligible to practice as an Advocate in
India, a person needs to fulfil the following
steps: (i) possess a law degree from a
recognised university; (ii) enroll in a State
Bar Council roll for a particular fee; and (iii)
qualify for the All-India Bar Examination
(“AIBE”). The specific eligibility requirements
prescribed under the Advocates Act are
discussed below.
The Advocates Act establishes the BCI
and State Bar Councils, as specified in the
legislation, to regulate the industry. BCI is
the apex regulatory body for Advocates in
India and undertakes the following functions,
among others: (i) lay down standards
of professional conduct and etiquette
for advocates; (ii) safeguard the rights,
privileges and interests of advocates; (iii)
exercise supervision and control over State
Bar Councils; (iv) recognise Universities
whose degree in law shall be a qualification
for enrolment as an advocate; (v) organise
legal aid to people experiencing poverty;
(vi) recognise, on a reciprocal basis, foreign
qualifications in law obtained outside India
for admission as an Advocate under this Act.

The State Bar Councils, on the other hand,
are empowered to undertake the following
functions amongst others: (i) admit persons
as Advocates on its roll; (ii) entertain and
determine cases of misconduct against
Advocates on its roll; (iii) safeguard the
rights, privileges and interests of Advocates
on its roll; (iv) manage and invest the funds
of the Bar Council.
The Bar Council of India Rules, 1975, and the
BCI Rules for Registration and Regulation of
Foreign Lawyers and Foreign Law Firms in
India, 2022 (amended and notified in 2025)
(“BCI Rules”), further regulate the presence
of Indian and international legal practitioners
in India.
2.4.2 Competencies of Professionals
to Render Legal Services
The Advocates Act lays down the following
conditions for Indian citizens and foreigners
to be enrolled as an Advocate in India: They
must (i)  be a citizen of India (a national
of any other country may be admitted as
an advocate on a State roll subject to the
provisions of this Act); (ii) have completed 21
years of age; (iii) have obtained a degree in
law from a recognised university, including a
foreign degree if the same is recognised by
BCI (The Advocates Act, 1961, section 24).
India offers legal education through a wide
network of national and state universities,
along with specialized law colleges, that
equip students to become practicing
lawyers. Interested candidates may attempt
the relevant entrance exam to obtain

India’s Services Sector: Insights on Regulatory Regime in Professional Services 22
admission to an institution and graduate
with a recognized degree. The law course
can be pursued either as a 3-year program
after an undergraduate degree or as a
5-year integrated program after completing
higher secondary education. Notably, vide
notification dated 27.09.2025, the BCI has
permitted final year, final semester candidates
without backlogs in the previous semester
to register for the AIBE. On obtaining a law
degree, the law graduate can provisionally
enroll with the State Bar Council of the
state where they intend to practice. Further,
such graduates are required to apply for the
AIBE and pass the same to regularize their
provisional enrolment with the State Bar
Council. On clearing the AIBE, they attain a
Certificate of Enrolment and an enrolment
ID, which enables them to practice as an
Advocate in India. This education regime does
not mandate any exit exam for candidates.
If an Indian citizen obtains a foreign law
degree as their first degree but intends to
practice law in India, they should complete
a bridge course prescribed by the BCI. In
2016, the BCI introduced a bridge course for
Indian students holding foreign law degrees
as their first degree, vide notification on the
‘Introduction of Bridge Course for Foreign
Law Degree Holders’, to bridge the gap
between the curriculum prescribed by the
BCI and that of foreign universities. This
bridge course, which spans one to two years,
is offered by select National Law Universities
in India. After completing the bridge course,
the candidate must appear for a Qualifying
Examination (QE) to attain equivalence
between their foreign degree and a
corresponding Indian degree. However, the
BCI vide ‘Notification relating to Recognition
by Bar Council of India of Foreign Universities’,
dated February 21, 2023, stated that any law
degree obtained by an Indian citizen from
a foreign university not recognised by the
BCI shall not be eligible for equivalency.
Such person shall not be eligible to appear
in the QE and shall also not be eligible to be
enrolled with any State Bar Council.
According to the BCI Rules 2022, foreign
lawyers duly qualified to practice law in their
home country can apply for registration with
the BCI, along with a non-refundable process
charge and certain documents, to provide
services in India. Any registration obtained
will remain valid for a period of 5 years and
must be renewed 6 months prior to its expiry
for continued presence in India. Any lawyer or
law firm so registered is entitled to practice
non-litigious matters in India and cannot
appear before any court or tribunal. They
are permitted to undertake work in advisory
and transactional matters, international law
or arbitration matters, and matters related to
the laws of their home country.
This BCI Rules 2022 was challenged before
the Delhi High Court (Narendra Sharma &
Ors. v. Bar Council of India & Ors., WP (C) No.
1556 of 2024), and the matter remains sub-
judice. Despite the ongoing litigation, the
BCI has revised and re-notified the rules in
May 2025, introducing key amendments and
clarifications. Under the newly notified rules,
foreign lawyers and law firms are still required
to register with the BCI to offer legal services
in India, but only in non-litigious matters
involving foreign law, international law, or
arbitration. This is part of BCI’s effort to
position India as a global hub for arbitration.
Foreign lawyers still cannot appear before
Indian courts, tribunals, or statutory
authorities, and the rules permit their entry
based on the principle of reciprocity. However,
vide press release dated 21.10.2025, the BCI
has expressed grave concerns over law firms
presenting themselves as integrated global
legal service platforms, which are often
structured through Swiss Vereins, exclusive
referral models, and co-branding initiatives
that mimic integrated global platforms.

India’s Services Sector: Insights on Regulatory Regime in Professional Services23
2.4.3 Other Restrictions for
Professionals Rendering Legal
Services
Until 2022, the presence of international
lawyers in India was limited by
the absence of a prescribed procedure
permitting them to provide legal services in
the country. Box 2. Snapshot of the Early History of Foreign Law Firms in India
In the 1990s, foreign law firms such as White & Case, Chadbourne & Parke, and Ashurst Morris
Crisp approached the Reserve Bank of India (RBI) for permission under section 29 of the now-
repealed Foreign Exchange Regulation Act, 1973, to establish liaison offices in India. The RBI
granted permission, but with certain restrictions limiting the entity’s functions strictly to that of
a liaison office. However, on December 16, 2009, the Bombay High Court held RBI’s decision to
be invalid in Lawyers Collective v. Bar Council of India and Others (Writ Petition No. 1526/1995).
The Court held that the activities of a liaison office are “inextricably linked” to the foreign law
firm’s head office, and that RBI’s authority under section 29 applied only to business entities,
not to legal professionals. It ruled that since legal practice is a profession and not a commercial
business, the RBI has no authority to grant permission to foreign law firms to establish liaison
offices in India. The Court also clarified that the Advocates Act covers both litigious and non-
litigious legal matters, and therefore, foreign lawyers cannot practice in India in any form. This
judgment effectively barred foreign law firms and lawyers from setting up a commercial presence
in the country. Despite the ban, many foreign entities have continued to collaborate with Indian
law firms through referral arrangements and knowledge-sharing partnerships.
In A.K. Balaji v. The Government of India &
ors (AIR 2012 Mad 124), the High Court of
Madras held that there was no bar on foreign
law firms or foreign lawyers to visit India for
a temporary period on a “fly in and fly out”
basis to provide legal advice to clients in
India on aspects of foreign law, international
law etc. but not Indian law. However, this
decision was overturned and modified by the
Supreme Court in Bar Council of India v. A. K.
Balaji and Ors (2018 (5) SCC 379), wherein
it was stated that only a mere casual visit
is permitted (not visits made on a regular
basis) and what constitutes “casual” was to
be decided on a case-by-case basis.
The law regarding entry and practice of
foreign lawyers in India has been formalised
by the BCI via the BCI Rules 2022, wherein
it is stated that a foreign lawyer or foreign
law firm may provide legal services in India
on matters of foreign law and international
issues by obtaining registration from the
BCI. However, to provide services on a “fly
in and fly out basis”, where the period of
practice does not exceed 60 days in a year,
such registration is not required. Thus, the
limitation on market access is as prescribed
under the BCI Rules.
Further, the domestic regulatory framework
does not offer national treatment to foreign
lawyers as the Advocates Act permits only
Indian citizens to be enrolled as “Advocates”.
The only exception, in theory, is reciprocity,
i.e. a foreign national may be admitted as an
advocate in India if duly qualified citizens of
India are permitted to practice law in that
country (The Advocates Act, 1961, sec 24(a),
47). 
As far as establishing commercial presence
in legal services is concerned, entities
providing legal services in India must operate
as sole proprietorships, partnership firms,
or LLPs and cannot function as companies.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 24
This condition is due to the restriction placed
under the BCI Rules, which states that an
Advocate shall not be a full-time salaried
employee of any person, Government, firm,
corporation, or concern (BCI Rules, 1975,
Chapter II, Rule 49). The adverse inference
of this rule is that since an Advocate cannot
be a salaried employee, a cohort of lawyers
cannot form an incorporated company with
salaried Advocates to provide legal services.
Additionally, advocates are also restricted
from entering into partnerships or any other
arrangement for sharing remuneration with
non-advocates (BCI Rules, 1975, Chapter
III, Rule 2), thus restricting multidisciplinary
practices in legal services.
Further, rule 36 under the BCI Rules
establishes a restriction on Advocates from
soliciting work or advertising, either directly
or indirectly, via any medium. Additional
conditions are placed on the size and content
of the concerned Advocate’s nameplate or
signboard as well (BCI Rules, 1975, Chapter
II, Rule 36). These restrictions are intended
to uphold the professional integrity and
ethical standards of the advocates and avoid
commercialisation of the industry. However,
in 2008, vide Resolution No. 50/2008, the
BCI amended rule 36, permitting Advocates
to maintain websites and furnish details such
as name, contact details, details of enrolment,
qualifications and area of practice therein,
provided a disclaimer is included attesting
the truth of such information.
Box 3. India’s Commitment in Legal Services under GATS and its FTAs
India, till date, has not undertaken commitments in legal services in its FTAs as well as GATS.
2.5 Accounting, Auditing and Bookkeeping Services
Accounting, auditing, and bookkeeping
services form the backbone of India’s financial
system. Accounting involves the classification,
summarisation, and interpretation of financial
data to produce accurate reports and ensure
compliance with regulatory standards.
Auditing provides an independent evaluation
of financial records, verifying their accuracy
and ensuring adherence to statutory
requirements. Supporting both these
functions, bookkeeping ensures precise,
credible and systematic documentation of
all financial transactions. Together, these
services promote transparency, uphold
regulatory compliance, and strengthen
financial governance across the economy.
While these services differ in their scope,
they are not defined under any specific
legislation. Instead, the scope of these
services is shaped by the laws that govern
the professionals who provide them. These
professionals primarily include Chartered
Accountants (CAs), Cost Accountants
(CMAs) and Company Secretaries (CSs),
regulated under specific statutes that outline
the boundaries of their practice. Auditors
form a specific class of CAs so qualified to
undertake auditing services. Taxation, though
a distinct service under the WTO’s services
sectoral classification list, is performed by
the same accounting professionals owing
to shared functions in these services. This
section would, thus, focus on the regulatory
landscape impacting the aforementioned
professionals.
RBI’s data on imports and exports from 2014-
15 to 2024-25 (Figure 5) shows that exports
rose from US$617 million to US$3,324 million
during this period. The second half of this
period exhibited a consistent and accelerating
growth, with exports surpassing the US$1
billion mark in 2019-20 and reflecting stable
year-on-year increases. Imports of these
services have shown a more volatile trend

India’s Services Sector: Insights on Regulatory Regime in Professional Services25
compared to exports. Imports increased from
US$81 million in 2014-15 to US$232 million
in 2018-19, but then experienced a sharp
decline in 2020-21 before recovering. The
data indicates that imports remained within
a relatively narrow range in the later years,
with a final value of US$181 million recorded
for 2024-25. This significant and consistent
upward trend highlights the expanding
demand for these professional services.
Figure 5. Trade in Accounting, Auditing, and Bookkeeping Services
Source: RBI data on invisibles
CAs handle a wide range of functions,
including accountancy (writing up accounts,
preparation of financial statements, etc.),
auditing (verification of financial statements,
compliance with accounting principles, etc.),
taxation (preparing tax returns, representing
assessees before the Income-Tax authorities,
rendering general tax advice, etc.) (Services
by CA, ICAI). CAs, along with CMAs, perform
cost accountancy functions which involve
ascertaining costing, certifying cost statements
and assisting in establishing selling prices. CSs
focus on legal and regulatory compliance, steer
corporate governance practices, and serve as
key intermediaries between companies and
their stakeholders. They also offer tax-related
advisory services, assist with tax planning,
oversee tax filings and represent businesses
before tax authorities (Role of Company
Secretary, ICSI). Though these professionals
undertake tax services, lawyers proficient in tax
laws may also undertake tax advisory services
or appear before tax authorities to the extent
permitted under Advocates Act and any other
applicable law.
When it comes to auditing services, India’s
regulatory framework requires businesses
to comply with several types of audits, each
governed by a different legal provision. The
different types of audits include:
(i) Statutory audits under section 139 of
the Companies Act, 2013, which a licensed
CA must conduct.
(ii) Internal audits under section 138 of
the Companies Act, 2013, which must be
carried out by a CA (other than the statutory
auditor), a CMA, or another professional
chosen by the Board.
(iii) Secretarial audits under section 204 of
the Companies Act, 2013, which a practicing
CS conducts.
(iv) Cost audits under section 148 of the
Companies Act, 2013, which a certified CMA
conducts.
(v) Tax audits under section 63 of the
Income Tax Act, 2025, which a practicing
CA can perform.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 26
Satyam Computer Services Limited v.
Directorate of Enforcement (2009), one
of India’s biggest cases of corporate fraud,
exposed certain vulnerabilities in the
auditing ecosystem and highlighted risks of
conflict of interest and collusion. The case
involved inflated revenues, falsified accounts,
and deliberate misrepresentation by top
management of the company, with external
auditors signing off on all resolutions,
leading to an estimated fraud of ₹7,000
crore (over US$1 billion). This prompted a
reassessment of the regulatory framework
governing financial practices, particularly in
areas of accounting, auditing, and corporate
governance.
Box 4. Genesis of NFRA
The National Financial Reporting Authority (NFRA) serves as the key regulatory body for auditing,
overseeing auditors and audit firms that serve listed companies, large unlisted public companies
(based on thresholds for net worth, paid-up capital, or turnover), and other entities specified by
the government. It was notified on 1st October, 2018 under section 132 of the Companies Act,
2013. As per rule 4 of the NFRA Rules, 2018 NFRA’s objective is to protect public interest and
the interest of investors, creditors, and others by establishing high quality accounting, auditing
standards, and exercising oversight over related functions. NFRA covers Public Interest Entities
(PIEs), including listed companies, certain unlisted companies, and entities in sectors like banking,
insurance, and power, as defined in rule 3 of the NFRA Rules.
(Source: Legal Opinion on NFRA vide letter dated 10.10.2024)
2.5.1 Legal and Regulatory
Framework for Professionals
Rendering Accounting, Auditing
and Bookkeeping Services
All three categories of professionals, i.e. CAs,
CMAs and CSs, are governed under different
legislative frameworks and statutory bodies
in India.
(i)
Chartered Accountants
The Chartered Accountants Act, 1949
(TCAA, 1949) regulates the profession of
CAs in India. It defines a CA as someone
who holds membership in the Institute
of Chartered Accountants of India (ICAI)
(TCAA, 1949, sec. 2(1)(b)). The Act
establishes the ICAI as a statutory body
entrusted with regulating the profession of
accountancy in the country. 
The ICAI performs various functions,
including: i) examination of candidates for
enrollment; ii) regulation of the engagement
and training of articled and audit assistants;
iii) maintenance and publication of a
Register of persons qualified to practice
as chartered accountants; iv) granting or
refusal of certificates of practice as per
guidelines issued by the Council (TCAA,
1949, sec. 15B).
The Chartered Accountants Regulations,
1988 (TCAR, 1988) supplement the
regulatory framework for CAs in India by
prescribing the necessary qualifications for
a CA.
As far as the accounting standards in India
are concerned, the central government
may prescribe the standards of accounting
as recommended by the ICAI in
consultation with and after examination of
the recommendations made by the NFRA
(TCA, 2013, sec. 133). Additionally, the ICAI
has developed comprehensive Auditing
and Assurance Standards (AAS 1 through
AAS 35), which provide detailed guidance
on various aspects of audit processes,
including audit planning, risk assessment,

India’s Services Sector: Insights on Regulatory Regime in Professional Services27
fraud detection, and auditor responsibilities,
thereby ensuring the integrity and reliability
of financial reporting in India (ICAI).
When a Chartered Accountant functions
as an auditor, several other laws apply
alongside the Chartered Accountants Act,
1949, including the Companies Act, 2013;
the Income Tax Act, 2025; the Companies
(Accounting Standards) Rules, 2021; the
Companies (Audit and Auditors) Rules,
2014; and the National Financial Reporting
Authority Rules, 2018.
(ii)
Cost Accountants
CMAs in India are governed by the Cost
Accountants Act, 1959 (TCMAA, 1959) and
the Cost and Works Accountants Regulation,
1959, with the Institute of Cost Accountants
of India (ICMAI) as the statutory body. The
profession was originally known as “Cost
and Works Accountants” and governed
under the same regulatory framework
through the Institute of Cost and Works
Accountants of India (ICWAI). ICWAI had
first been established in 1944 as a registered
company under the erstwhile Companies
Act to promote, regulate, and develop cost
accountancy, before being reconstituted
as a statutory body in 1959. The Cost and
Works Accountants (Amendment) Act,
2011 subsequently renamed the profession
as “cost accountants” and the institute
as ICMAI, reflecting its renewed focus on
developing and advancing the field of Cost
and Management Accounting (Institute of
Cost and Works Accountants of India, Press
Release, 2012).
ICMAI performs various functions in relation
to Cost Accountants in India, namely: i)
conduct of examination for  candidates
for enrollment; ii) regulation of training of
students; iii) maintenance and publication
of a Register of persons qualified to
practice as Cost Accountants; iv) collection
of fees from members, examinees and
other persons; v) removal of names
from the Register and the restoration to
the Register of names which have been
removed; vi) maintenance of a library
and publication of books and periodicals
relating to accountancy and allied subjects;
vii) conduct of elections to the Council of
the Institute; and viii) grant or refusal of
certificates of practice as per guidelines
issued by the Council.
(iii)
Company Secretaries
CSs in India are governed by the Company
Secretaries Act, 1980 (TCSA, 1980). It
defines CS as “a person who is a member
of the Institute” (TCSA, 1980, sec. 2(c)).
The institute here refers to the Institute of
Company Secretaries of India (ICSI) (TCSA,
1980, sec. 2(g)). 
The Council of ICSI performs the functions
laid down in the TCSA, i) approving
academic courses and their contents; ii)
prescribing  qualifications for entry in the
Register of members; iii) recognising foreign
qualifications and training for purposes
of enrolment; iv) prescribing  guidelines
for granting or refusal of certificates of
practice under the TCSA; v) entering into
memorandum or arrangement with the
prior approval of the Central Government
with any agency of any foreign country for
the purpose of performing its functions
under this Act (TCSA, 1980, sec. 15). ICSI
performs the following functions: i) conduct
of examination of candidates for enrolment;
ii) regulation of training of students; iii)
maintenance and publication of a Register
of persons qualified to practice as Company
Secretaries; iv) conduct of elections to the
Council of the Institute, etc. (TCSA, 1980,
sec. 15A). 
The Company Secretaries Regulations, 1982
(TCSR, 1982) further regulate CSs in India.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 28
(iv)
Bookkeepers
The profession of bookkeeping is subject
to various legal requirements in India,
though not governed by a dedicated
regulatory framework. The Income Tax Act,
2025 defines “books or books of account”
to include ledgers, day books, cash books,
account books, and other books, whether
kept in written form, electronic/ digital
form or as print-outs from data stored in
electronic form etc. (The Income Tax Act,
2025, sec. 2(19)). The Companies Act, 2013
requires companies to maintain proper
books of account (TCA, 2013, sec. 128). The
GST Act, 2017 mandates every registered
person required to maintain books of
accounts under section 35(1) to retain
them for seventy-two months from the due
date of furnishing of annual return for the
relevant year (GST Act, 2017, sec. 36).
2.5.2 Competencies of Professionals
to Render Accounting, Auditing and
Bookkeeping Services
While accounting, auditing and bookkeeping
services can be rendered by any individual
who fulfills the required educational and
technical qualifications, CAs, CMAs, and
CSs typically render the titled services. This
part of the chapter covers the educational
qualifications and licensing requirements for
these professionals.
(i) Chartered Accountants
To qualify as a CA, an individual must
undergo a three-tier process, followed by
qualifying exams. The three-tier process is
as follows:
• CA Foundation course (TCAR, 1988, reg.
25E, 25 F): All candidates must clear the
CA Foundation course to begin the three-
tier process of becoming a CA. This stage
is equivalent to an entrance examination
in other courses and was previously
known as the Common Proficiency Test.
Interested candidates may attempt this
directly after the successful completion
of their 10+2 grade.
• CA Intermediate course (TCAR, 1988,
reg. 28F): After clearing the foundation
course, candidates must undertake the
intermediate course. Any candidate
venturing to undertake the CA courses
after completing their 10+2 grade
must complete the foundation course
mandatorily. However, candidates
who hold a graduate or postgraduate
degree in commerce with at least 55%
marks, or in other disciplines with at
least 60% marks, can directly register
for the intermediate course without
taking the foundation exam.
• Articleship Training (TCAR, 1988, reg.
45): All aspirants, on the successful
completion of their intermediate course,
should undertake an articleship training
with a qualified CA for a period of two
years. A certificate of the successful
completion of this training is necessary
to be eligible for the membership of
ICAI.
• CA Final Course (TCAR, 1988, reg. 29D):
The final step to qualify as a CA is the CA
final course, the successful completion
of which will enable the candidate to
function as a fully qualified CA.
In addition to the abovementioned steps,
the Council of the ICAI may prescribe
further qualifications from time to time
which the aspirants will need to fulfil to be
eligible to practice as a CA. A few examples
of such training are General Management
and Communication Skills (GMCS) training,
ICITSS (Integrated Course on Information
Technology and Soft Skills) (TCAR, 1988,
reg. 51B) etc.
Once a candidate has completed all the
required qualifying steps, they can apply
for membership with the ICAI, which allows

India’s Services Sector: Insights on Regulatory Regime in Professional Services29
them to practice as a Chartered Accountant.
However, to legally practice as an auditor,
TCAA, 1949, requires the qualified candidates
to obtain a certificate of practice from the
ICAI. The institute issues this certificate upon
payment of a fee, without requiring any
additional qualifying exams. Notably, only
practicing CAs with certificate of practice
are eligible to be appointed as company
auditors (TCA, s.141).
(ii)
Cost Accountant
To become a qualified CMA, an interested
candidate must complete a three-tier
course and examination structure. This is
detailed in the Cost and Works Accountants
Regulation, 1959 (TCWAR, 1959), as follows:
• Foundation course (TCWAR, 1959,
reg. 20A):  All candidates interested
in becoming a CMA may apply for the
foundation course upon successful
completion of their Class 10, Class
10+2, National Diploma in Commerce
Examination by AICTE, or Diploma in
Rural Service Examination. Candidates
admitted after class 10 or mere
appearance in class 10+2 exam will only
receive a provisional candidature, and
the same will be regularized only on the
submission of the pass certificate of class
10+2 examination, within 36 months of
admission to the foundation course.
• Intermediate Course (TCWAR, 1959,
reg. 30): On the successful completion
of the foundation course or on the
completion of an undergraduate course
from a recognised university, candidates
may apply for the intermediate course.
• Final Course (TCWAR, 1959, reg. 33):
This is the final step in the course
structure of a prospective CMA. A
successful completion of the final
course will enable the aspirant to
obtain membership of the institute and
function as a fully qualified CMA.
• Practical Training (TCWAR, 1959, reg.
44): Candidates who complete the
prescribed examinations must undergo
a minimum of three years of practical
training, as mandated by the council, to
qualify for full associate membership
(ACMA). This requirement applies
to anyone who clears ICMAI’s exams
or holds qualifications that ICMAI
recognizes as equivalent, whether
earned in India or abroad. As long
as the qualification is recognized by
ICMAI and the candidate completes
the required practical training, they are
eligible for membership in ICMAI.
Similar to CAs in India, CMAs do not have
an exit exam that qualifies them for practice.
Upon completing the prescribed educational
qualification, a candidate may apply and
obtain membership at the ICMAI. All such
duly qualified CMAs must obtain a certificate
of practice from the Council of ICMAI, which
enables them to practice as CMAs in India.
This certificate is obtained for a fee and not
through any exams. (TCMAA, 1959, sec. 6;
TCWAR, 1959, reg. 10). 
(iii)
Company Secretaries
Any CS aspirant who has attained the age of
21 may pursue the prescribed qualifications.
The qualification process consists of three
stages:
• Foundation Programme:  Previously,
any aspirant who completed 10+2
grade could enroll for the foundation
programme. This is now replaced by
CSEET (refer to point 2 below).
• Executive Programme: Any Indian
aspirant who has graduated 10+2 grade
and has passed the Company Secretary
Executive Entrance Test (CSEET) can
enroll in this course.
• Professional Programme: On completing
the executive programme, candidates
may enroll in the professional programme.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 30
• Practical Training: Candidates who have
completed the professional programme
will become eligible for membership
in ICSI only on the completion of
practical training, as prescribed under
the applicable law (The Company
Secretaries (Amendment) Regulations,
2020, reg. 46BA, 46BB).
CS aspirants do not have an exit exam that
qualifies them for practice. On completion
of the prescribed educational qualification,
an aspirant may apply and obtain a
membership at ICSI. All duly qualified CSs
ought to obtain a Certificate of Practice
from the Council of ICSI to be able to
practice as a CS in India or elsewhere. This
certificate is obtained for a fee and does
not require an exam.
(iv)
Bookkeepers
Since no specific qualification requirements
are prescribed under Indian law,
bookkeeping services may be offered
by individuals with varied educational
backgrounds.
2.5.3 Other Restrictions for
Professionals Rendering Accounting,
Auditing and Bookkeeping Services
(i) Chartered Accountants
There exists no citizenship requirement
for individuals to become chartered
accountants, auditors, or bookkeepers in
India. However, the proviso to section 4(1)
(v) and Appendix 7 of the TCAA, 1949,
empower the ICAI and central government
to impose additional conditions on non-
residents seeking entry in the register of
members maintained by ICAI. Additionally,
participation or practice of foreign
professionals and the scope of their
work are also defined by Memorandum
of Understanding (MoUs) and Mutual
Recognition Agreements (MRAs) signed
by the ICAI with its corresponding
foreign institutions. These agreements
facilitate global professional
mobility, allowing qualified members of
both the ICAI and foreign accounting bodies
to gain membership in the concerned
institutes.
Box 5. List of Qualification Reciprocity Arrangements by ICAI
• Memorandum of Understanding between ICAI and Chartered Accountants – Australia and
New Zealand (CAANZ)
• Mutual Recognition Agreement between ICAI and the Institute of Chartered Accountants of
Nepal (ICAN)
• Mutual Recognition Agreement with The Malaysian Institute of Certified Public Accountants
(MICPA)
• Memorandum of Understanding with The Institute of Chartered Accountants in England and
Wales
• Memorandum of Understanding with Chartered Professional Accountants of Canada (CPA
Canada)
• Mutual Recognition Agreement with the Institute of Certified Public Accountants in Ireland
(CPA Ireland)
• Mutual Recognition Agreement with the South African Institute of Chartered Accountants
(SAICA)
• Mutual Recognition Agreement (MRA) with CPA Australia
(Source extracted on 19.09.2025: MoU/MRA/Joint Declarations signed with Foreign Bodies, ICAI (2025))

India’s Services Sector: Insights on Regulatory Regime in Professional Services31
Box 6. List of Unilateral Agreements/Pilot International Pathway Programme
• ICAI members can become the members of Malaysian Institute of Accountants (MIA)
• ICAI Members in Singapore are now eligible to become ISCA Associate Member
• International Pathway Programme of Chartered Accountants Australia & New Zealand
• International Pathway Programme of the Institute of Chartered Accountants of England & Wales
(ICAEW)
• License Agreement with ISACA
(Source extracted on 19.09.2025: MoU/MRA/Joint Declarations signed with Foreign Bodies, ICAI (2025))
An MRA between ICAI and a corresponding
foreign body enables qualified Indian CAs
to obtain equivalency and the right to
practice in that country, typically through
bridge courses and other such mechanisms.
In countries without such agreements,
Indian CAs must meet all local legal
requirements, just as foreign CAs must do
in India. Additionally, the ICAI Council may
set conditions under which it recognises
foreign qualifications for membership. The
law also provides for negative reciprocity
i.e. if a foreign country discriminates against
Indian CAs or bars them from joining their
CA institute, then nationals of that country
will not be permitted to practice the
profession in India (TCAA, sec. 29).
Further, any entity providing chartered
accountancy services in India must operate
as a sole proprietorship, partnership, or
LLP. Section 25 of TCAA, prohibits CA firms
from being incorporated as a company.
Additionally, the first schedule of TCAA
read with TCAR permits CAs to enter into
fee and/ or profit-sharing arrangements
(TCAA, First Schedule, Part I, clause 2 and
3) and partnerships (TCAA, First Schedule,
Part I, clause 4 and 5) with non-CA
professionals. Such non-CA professionals
are particularly identified under TCAR, 1988,
for fee and/ or profit-sharing arrangements
(TCAR, 1988, regulation 53A) and for multi-
disciplinary partnerships (TCAR, 1988,
regulation 53B). Further, the ICAI notified
certain guidelines in 2021 pertaining to the
formation of multi-disciplinary partnerships
to guide such endeavours.
In India, CAs are prohibited from advertising
their services (TCAA, Schedule I). Clause 6
under Part I of the first schedule to TCAA
prohibits CAs from soliciting clients/
professional work, directly or indirectly, via
any medium, and clause 7 under Part I of
the first schedule to TCAA prohibits the
advertisement of professional attainments
or services, as well as the usage of
designations other than CA. Violation
of these restrictions will be considered
a professional misconduct in relation to
chartered accountants in practice. However,
the proviso to clause 7 permits members
to advertise through a write-up, subject to
guidelines issued by the Council. As of April
2026, ICAI has relaxed these restrictions
by permitting fact-based professional
advertising, granting greater creative
flexibility in advertising "write-ups," and
explicitly allowing "push technology" to
enable Indian firms to enhance visibility
and compete globally (ICAI Press Release
dated 12 December, 2025).
(ii)
Cost Accountant
There is no citizenship requirement for
individuals to become cost accountants in
India. However, the proviso to section 4(1)
(iv) of the TCMAA, 1959, empowers the
ICMAI and central government to impose
additional conditions on non-residents
seeking entry in the register of members

India’s Services Sector: Insights on Regulatory Regime in Professional Services 32
maintained by ICMAI. Additionally, ICMAI
has signed various MoUs with corresponding
foreign bodies to mutually recognise
qualifications, promote collaborative
activities, exchange knowledge, and
enhance technical cooperation. These
MoUs define the scope of practice and
study for international candidates in India.
Below are a few of the key MoUs:
Box 7. List of MoUs by ICMAI
• Institute of Public Accountants (IPA), Australia
• Chartered Institute for Securities and Investment, UK (CISI)
• Chartered Institute of Public Finance and Accountancy (CIPFA), UK
• Institute of Certified Management Accountants of Sri Lanka
• Chartered Institute of Management Accountants (CIMA), UK
• National Institute of Accountants, Australia (NIA)
• The Association of Chartered Certified Accountants (ACCA), UK
(Source extracted on 19.09.25: MoU/MRA/Joint Declarations signed with Foreign Bodies, ICAI (2025))
These MoUs provide bridging requirements
for qualified personnel to attain equivalency
in regards to a corresponding foreign
Organisation. The legislation also discusses
negative reciprocity, i.e. if any foreign
nation accords discriminatory treatment
to Indian domiciled CMAs, prevents them
from becoming members in corresponding
institutes in such countries or prevents them
from practicing the profession, members
of such countries shall not be permitted to
practice the profession in India or become
members of the ICMAI (TCMAA, 1959, sec. 38).
In India, an entity providing cost
accountancy services may be structured
as a sole proprietorship, partnership, or
LLP. CMA firms are prohibited from being
incorporated as a company (TCMAA, 1959,
sec. 26). Further, the first schedule of
TCMAA, read with TCWAR, permits CMAs
to enter into fee and/ or profit-sharing
arrangements (TCMAA, First Schedule,
Part I, clause 2 and 3) and partnerships
(TCMAA, First Schedule, Part I, clause 4
and 5) with non-CMA professionals. This
legal position, thus, paves the way for the
formation of multi-disciplinary practices.
Regulations 111B and 111C of the TCWAR,
identify particular non-CMA professionals
who are permitted to form fee/profit-
sharing and partnership arrangements
with CMAs. The ICMAI has also released
draft guidelines for the formation of multi-
disciplinary practices for public comments
(Institute of Cost Accountants of India,
2021). 
In terms of advertising rights, CMAs had
the same position as that of CAs. The first
schedule to TCMAA prohibits them from
soliciting clients/professional work and
from advertising professional attainments
or services (TCMAA, Schedule I, Clauses 6
and 7). Violation of these restrictions will
be considered a professional misconduct.
However, the proviso to clause 7 permits
a member in practice to advertise through
a write-up, subject to guidelines issued
by the Council. The Council Guidelines
for Advertisement, 2025, for Members
in Practice provides a structured and
streamlined mechanism for advertisements
according to the guidelines.
(iii)
Company Secretaries
There is no citizenship requirement for
individuals to become company secretaries
in India. However, the proviso to section 4(1)
(e) of the TCSA, 1980, empower the ICSI and
central government to impose additional
conditions on non-residents seeking entry

India’s Services Sector: Insights on Regulatory Regime in Professional Services33
in the register of members maintained by
ICMAI. Foreign qualifications will also be
recognized if aspirants are members of
the Chartered Governance Institute (CGI),
London, since ICSI has entered into an
MRA with ICSA. This agreement allows
reciprocal membership for members of
both the Institutes, subject to obtaining
certain prescribed qualifications.
The legislation also discusses negative
reciprocity, i.e., if any foreign nation accords
discriminatory treatment to Indian CSs or
prevents them from becoming members in
corresponding CS institutes in such countries,
members of such countries shall not be
permitted to practice the profession in India.
The Council of ICSI may prescribe conditions
based on which foreign qualifications may
be recognised for membership in ICSI (TCSA,
1980, sec. 38).
Any entity providing company secretary
services can be a sole proprietorship, a
partnership, or an LLP. A CS enterprise is
prohibited from being an incorporated
company (TCSA, 1980, sec. 26). Further,
the first schedule of TCSA, read with TCSR,
1982, permits CSs to enter into fee and/ or
profit-sharing arrangements (TCSA, 1980,
First Schedule, Part I, clause 2 and 3) and
partnerships (TCSA, 1980, First Schedule,
Part I, clause 4 and 5) with non-CS
professionals. Such non-CS professionals
are particularly identified under TCSR, 1982
for fee and/ or profit-sharing arrangements
(TCSR, 1982, regulation 168A) and for
multi-disciplinary partnerships (TCSR,
1982, regulation 168B). Further, the ICSI
particularly permits the formation of multi-
disciplinary partnerships under Regulation
165A of TCSR, 1982. The Council maintains a
register of members of the Institute, which
include each members’ full name, date of
birth, domicile, residential and professional
addresses TCSA 1980, sec. 19(1)).
CSs in India experience restrictions similar
to those of CAs and Cost Accountants in
advertising their services. The first schedule
to TCSA prohibits CSs from soliciting
clients/professional work via any means
(TCSA, 1980, Schedule I, Clause 6) and
from advertising professional attainments
or services or using designations other
than as prescribed (TCSA, 1980, Schedule
I, Clause 7). Violation of these restrictions
will be considered professional misconduct
on the part of the CS. However, certain
exceptions are provided, permitting
response to tenders or advertising through
a write-up, subject to guidelines issued by
the Council. Further, the ICSI has notified
the ICSI (Guidelines for Advertisement by
Company Secretaries), 2020, to regulate
advertising and publicity of professional
services specifically. The ICSI (Management
and Development of Company Secretaries
in Practice) Guidelines, 2023, provide a
comprehensive framework for professional
practice, including firm management,
service areas, including branding and
advertisement.
Box 8. India’s Commitment in Accounting, Auditing and Bookkeeping Services
under GATS and its FTAs
India has not committed to accounting, auditing and bookkeeping services under GATS.
Accounting and bookkeeping services
As far as accounting and bookkeeping services are concerned, India has not placed any
limitation on market access and national treatment for the supply of services through Mode
1 (cross-border trade) and Mode 2 (consumption abroad) in its FTAs with Korea, Japan,
Singapore, Malaysia, Mauritius, Australia, the United Arab Emirates (UAE), the European Free
Trade Association (EFTA), and the UK.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 34
Further, there is a total restriction on market access and national treatment for the supply of
services through Mode 3 (commercial presence) in all of India’s FTAs except for its FTA with
the UK, where there are no restrictions on market access and national treatment on the supply
of services through this mode. Market access is, however, subject to the limitations on the
permissible forms of establishment, which are: sole proprietorship, partnership or limited liability
partnership firms. 
Market access for the supply of services through Mode 4 (temporary movement of natural
persons) is subject to the limitations on entry and stay for specific categories of services
suppliers, including business visitors, intra-corporate transferees, contractual services suppliers,
independent professionals, installers or servicers, and accompanying spouse and dependents
as prescribed under horizontal commitments in India’s schedule of commitments in trade in
services, chapter or annex on movement of natural persons in these FTAs. Market access for
supply of services through Mode 4 in India-Singapore FTA is subject to the additional condition
of obtaining professional indemnity insurance from home country for a period of stay upto 12
months.
National treatment for the supply of services through Mode 4 is also further subject to the requirement
of obtaining professional indemnity insurance from the home country of the service provider.
Additionally, national treatment for the supply of services through Modes 1, 2, and 4 is subject to
the limitation that services requiring the use of the title of Chartered Accountant or Cost & Works
Accountant under applicable domestic laws can be rendered only subject to registration with
the relevant professional body under a scheme of reciprocity. This condition is present in India’s
FTAs with Australia, EFTA, Mauritius and UAE. However, in India’s recent FTA with the UK, this
condition is applicable to all the four modes of supply. 
Auditing services
India has committed to auditing services only in its recent FTA with the United Kingdom (UK);
this sub-sector has not been committed in India’s other FTAs. The UK’s service providers face
complete restrictions on market access and national treatment for the supply of services through
Mode 1 in this sub-sector.
The supply of services through Mode 2 is not subject to any market access limitations. For the
supply of services through Mode 3, there are no limitations on market access, however, market
access for this mode of supply is subject to the condition that commercial presence can only take
the form of sole proprietorship, partnership or limited liability partnership firms. Further, there are
no limitations on national treatment for the supply of services through Modes 2 and 3. 
Market access and national treatment for the supply of services through Mode 4 is subject to
the limitations on the categories of service suppliers in the horizontal section of the schedule
of commitment in the FTA. Additionally, national treatment for the UK service suppliers is
further subject to the requirement of obtaining professional indemnity insurance from the UK.
Furthermore, national treatment for Modes 2, 3, and 4 requires that services requiring use of the
title of Chartered Accountant or Cost & Works Accountant under applicable domestic laws can
be rendered only subject to registration with the relevant professional body under a scheme of
reciprocity.

India’s Services Sector: Insights on Regulatory Regime in Professional Services35
2.6 Architectural Services
Architectural services drive infrastructure
development in India. It encompasses design,
planning, and consultancy for residential,
commercial, and infrastructure projects.
Rapid urbanisation and modernisation drive,
with a growing focus on sustainability, have
propelled this sector. Despite its potential,
trade in architectural services in India remains
modest, offering significant opportunities
for growth. The RBI’s data on exports and
imports from 2014–15 to 2024–25 (Figure 6)
shows that exports increased from US$603
million to US$793 million during this period.
At the same time, imports decreased from
US$416 million in FY15 to US$305 million in
FY25.
Figure 6. Trade in Architectural Services
Source: RBI data on invisibles
The modest trade figures indicate an
opportunity to boost growth in the subsector.
The government’s focus on initiatives, such
as the Smart Cities Mission, Housing for
All, and other large-scale construction and
infrastructure projects, is likely to cause a
surge in demand for skilled professionals in
this sector.
2.6.1 Legal and Regulatory
Framework for Professionals
Rendering Architectural Services
The Architects Act, 1972 (TAA, 1972),
governs the practice of architecture in India
through a structured regulatory framework.
It seeks to safeguard the profession by
preventing unqualified individuals from
providing architectural services and ensuring
compliance with prescribed standards. To
this end, TAA mandates the registration of
architects (TAA, 1972, secs. 25–35), specifies
recognised qualifications in its schedule
(TAA, 1972, sec. 14), and prescribes standards
of practice. The Council of Architecture
(CoA), established under the TAA, is the
statutory body that oversees the profession
by maintaining standards for education,
licensing, and practice (TAA, 1972, sec.
3). To support this framework, the central
government is empowered to formulate rules
under TAA, while the CoA is authorised to
develop regulations as outlined in TAA.
The CoA regulations and guidelines set
minimum standards for architectural
education at undergraduate, postgraduate,
and diploma levels. They outline eligibility
criteria, course durations, structures, and
professional examination requirements. The

India’s Services Sector: Insights on Regulatory Regime in Professional Services 36
CoA’s Samarthaya Portal also facilitates
knowledge sharing, research collaboration,
online skill training, digital library access,
research publication, awards management,
and placement opportunities between
architects and schools. TAA includes a single
schedule, mentioned under section 14, that
lists the recognised qualifications from Indian
and foreign universities. It also prescribes the
process for recognising qualifications from
universities not included in the schedule,
ensuring that architectural education and
practice in India align with the required
standards of quality and competence (TAA,
1972, secs. 14, 15).
Indian universities granting architectural
qualifications not listed in the Schedule of
the Architects Act can apply to the Central
Government for recognition. After consulting
the CoA, the government may amend the
Schedule to include these qualifications
and set a recognition date (TAA, 1972, sec.
14). Additionally, the CoA can negotiate
with its foreign counterparts to establish
reciprocity agreements for recognising
foreign qualifications (TAA, 1972, sec. 15). In
the absence of a reciprocity agreement, the
government may, in consultation with the
CoA, recognise architectural qualifications
granted by foreign universities through a
notification published in the Official Gazette.
The CoA regulates the professional conduct
of architects through the Architects
(Professional Conduct) Regulations, 1989
(TAPCR, 1989). Regulation 2 of TAPCR
requires architects to apply their skills to
the creative, responsible, and economic
development of their country. It also urges
architects working in other countries to
observe the code of conduct applicable in
such countries. The CoA strictly prohibits
unethical practices such as offering or
accepting commissions, supplanting peers, or
engaging in unauthorised advertising, except
when explicitly allowed under established
guidelines. Adherence to the standards in the
regulation is mandatory, and any violation is
treated as professional misconduct (TAPCR,
1989, reg. 2).
2.6.2 Competencies of Professionals
to Render Architectural Services
The undergraduate architectural education in
India is regulated through the CoA (Minimum
Standards of Architectural Education)
Regulations, 2020 (COAMSAER, 2020).
To enroll in the Bachelor of Architecture
(B.Arch.) program, candidates must qualify
the 10+2 examination or a 10+3 diploma
and qualify an aptitude test (COAMSAER,
2020, reg. 4), such as the National Aptitude
Test in Architecture (NATA) or the Joint
Entrance Examination (JEE-Main/Advanced).
Additionally, the Architecture Aptitude Test
(AAT) is also conducted to get admission to
the B.Arch courses offered by the IIT BHU,
IIT Kharagpur, and IIT Roorkee, and only the
candidates who qualify for the JEE Advanced
are eligible to appear for the AAT exam (Joint
Entrance Examination (Advanced), 2026).
The All-India Council for Technical Education
(AICTE) coordinates the development of
technical education in the country, including
architecture (AICTE Act, 1987, sec. 10(b)).
However, its role in architecture education
has been clarified as secondary to that of
the CoA. The Hon’ble Supreme Court, All
India Council for Technical Education v. Shri
Prince Shivaji Maratha Boarding House’s
College of Architecture & Ors. (AIRONLINE
2019 SC 1422), categorically held that “so far
as recognition of degrees and diplomas of
architecture education is concerned, the 1972
Act shall prevail. AICTE will not be entitled to
impose any regulatory measure in connection
with the degrees and diplomas in the subject
of architecture. Norms and Regulations set
by CoA and other specified authorities under
the 1972 Act would have to be followed
by an institution imparting education for

India’s Services Sector: Insights on Regulatory Regime in Professional Services37
degrees and diplomas in architecture.” The
Court thus made it explicit that AICTE would
not have regulatory control over institutions
imparting architecture education, with CoA
retaining primary authority for accreditation
and regulation. AICTE’s involvement is
consequently limited to its broader mandate
of technical education, without extending
to the regulatory oversight of architecture
programs, which falls within the distinct
statutory domain of the CoA.
The five-year B.Arch. programme follows a
learner-centric Choice-Based Credit System
and includes practical training (COAMSAER,
2020, app. A). Students must earn the required
credits and complete the course within eight
years, with a one-year extension allowed in
exceptional cases (COAMSAER, 2020, reg.
3(6)). There is no exit examination at the end
of the course, instead the candidates have to
qualify all the papers at the university level
to obtain a B.Arch. degree. After a candidate
receives the B.Arch degree, they must have
their name entered in the register maintained
by CoA to practice architecture in India (TAA,
1972, sec. 23(2)).
A master’s degree (M.Arch.) is not mandatory
for obtaining a license to practice as an
architect, but architects can pursue such a
specialization. Subjects offered as modules
and electives in the B. Arch curriculum are
also available as specialization options in
M.Arch programs. Admission to M.Arch
programs require candidates to clear the
Postgraduate Entrance Test in Architecture
(PGETA), and such other qualifications as
specified by the CoA (Minimum Standards
of Architectural Education for Post-Graduate
Degree Programme) Guidelines, 2022. The
M.Arch course spans two years and must be
completed within a maximum of three years.
Upon earning the degree, architects can add
additional qualifications to the register by
paying the prescribed fee.
A person can register as an architect in India
by paying the required fee if they reside
or practice in the country and possess a
recognised architectural qualification (TAA,
1972, sec. 25). Foreigners can register in India
only if their qualifications are recognised
under section 15(1) of TAA, and Indian citizens
with similar qualifications can reciprocally
register and practice in such country, or if
the central government has approved the
qualification under a reciprocity agreement.
Notably, only registered individuals or a
firm of architects are entitled to use the title
‘architect’ (TAA, 1972, sec. 37(1)).
However, in Mukesh Kumar Manhar and
Anr. v. State Of Madhya Pradesh and Ors.
(2005(4) MPHT 270), the Division Bench of
the Hon’ble Madhya Pradesh High Court held
that the statement of objects and reasons of
the Architects Act states that the legislation
is intended to protect the title of ‘architects’,
but does not intend to make the design,
supervision and construction of buildings an
exclusive responsibility of architects. Other
professionals like engineers, are free to
engage themselves in similar responsibilities
in respect of building construction work,
provided they do not style themselves as
architects. In the Council of Architecture v.
Mr. Mukesh Goyal & Ors. (AIR 2020 SC 1736),
the Hon’ble Supreme Court of India held
that section 37 of TAA does not prohibit
individuals not registered under TAA, 1972
from undertaking the practice of architecture
and cognate activities.
Apart from the CoA, the Indian Institute of
Architects (IIA), a professional body, actively
supports and represents architects in India. It
has state-level organisations called Chapters,
which operate at the state and union territory
level to promote the architectural profession
throughout India. These chapters are part
of the IIA’s broader network of centers and
sub-centers, enabling the national body to
engage with architects and the public at the

India’s Services Sector: Insights on Regulatory Regime in Professional Services 38
regional level.  The IIA works to enhance the
aesthetic, scientific, and practical aspects
of architecture. It promotes planning and
building practices by advancing architectural
education, training, and standards. The
IIA upholds high standards of practice
among architects and fosters collaboration
through its membership categories, which
include Honorary Fellow, Fellow, Associate,
Licentiate, Retired Fellow, Retired Associate,
and Retired Licentiate, thereby contributing
significantly to the growth and recognition
of the field in India.
2.6.3 Other Restrictions
for Professionals Rendering
Architectural Services
There is a residency requirement to render
architectural services. Section 25 of TAA,
1972, stipulates that a person is entitled
to registration if they reside or carry on
the profession of an architect in India. The
proviso to Section 25 further stipulates that
foreigners shall be entitled to registration
by virtue of a qualification only if Indian
architects are permitted to enter and practice
the profession in their home country and if
their qualification is a recognised qualification
under Section 15(2) of TAA, 1972.
As far as the forms of establishment are
concerned, TAA, 1972, does not explicitly lay
out the forms of establishment permissible
to render architectural services. Section 37(1)
of TAA, 1972, only stipulates that no person
other than a registered architect, or a firm
of architects, shall use the title and style of
architect. Therefore, Limited Companies,
Private/Public Companies, societies and
other juridical persons are not entitled to
use the title and style of architect, nor are
they entitled to practice the profession
of architecture (Council of Architecture).
However, the Hon’ble Delhi High Court in
Sudhir Vohra v. Registrar of Companies and
Ors. (AIRONLINE 2018 DEL 51) held that TAA,
1972, neither prescribes that only registered
architects can provide architectural
services, nor contains any clause prohibiting
companies and LLPs from providing
architectural services. The Act only prohibits
the use of the title and style of ‘architect’
by unregistered natural persons or juristic
entities, such as LLPs and companies. It does
not prevent unregistered persons, including
juristic entities, from rendering architectural
services. Accordingly, companies or LLPs
providing architectural services could be
incorporated without an approval/NOC from
the CoA.
The Architects (Professional Conduct)
Regulations, 1989 (TAPCR, 1989), impose
advertising restrictions on architects.
Regulation 2(1)(xxv) stipulates that an architect
shall not advertise his professional services
nor shall he allow his name to be included in
an advertisement or to be used for publicity
purposes, save for the following exceptions:
(i) a notice of change of address may
be published on three occasions and
correspondents may be informed by post,
(ii) an architect may exhibit his name
outside his office and on a building, either
under construction or completed, for which
he is or was an architect, provided the
lettering does not exceed 10 cm. in height,
(iii) advertisements including the name and
address of an architect may be published
in connection with calling of tenders, staff
requirements and similar matters,
(iv) may allow his name to be associated
with illustrations and descriptions of his
work in the press or other public media but
he shall not give or accept any consideration
for such appearances,
(v) may allow his name to appear in
advertisements inserted in the press by
suppliers or manufacturers of materials
used in a building he has designed, provided

India’s Services Sector: Insights on Regulatory Regime in Professional Services39
his name is included in an unostentatious
manner and he does not accept any
consideration for its use,
(vi) may allow his name to appear in a
brochure prepared by the clients for the
purpose of advertising or promoting projects
for which he has been commissioned,
(vii) may produce or publish brochures,
pamphlets describing his experience
and capabilities for distribution to those
potential clients whom he can identify by
name and position,
4 The FIPB was abolished in 2017; such approvals are currently processed through the Foreign Investment Facilita-
tion Portal in DPIIT.
(viii) may allow his name to appear in the
classified columns of the trade / professional
directory and/or telephone directory/
website.
Further Regulation 2(1)(xiv) of TAPCR, 1989
stipulates that an architect “shall not prepare
designs in competition with other architects
for a client without payment or for a reduced
fee (except in a competition conducted
in accordance with the Architectural
competition guidelines approved by the
Council)”.
Box 9. India’s Commitment in Architectural Services under GATS and its FTAs
India has not committed to architectural services under GATS.
In its FTAs with Korea, Japan, Malaysia, Mauritius, Australia, the UAE, EFTA, and the UK, India has
not placed any limitations on market access or national treatment for the supply of architectural
services through Modes 1 and 2. Service suppliers from these countries can access the Indian
market freely under these modes, as India has completely liberalized this sub-sector for them.
However, under its FTA with Singapore, India requires that an architect be physically present in
India and licensed by the CoA carry out the implementation for these modes of supply.
For Mode 3, India permits market access only through incorporation as a partnership firm
consisting of architects across all its FTAs. Additionally, in its FTA with the UK, India has
specified commercial presence to be established as a sole proprietorship or a partnership firm.
India does not impose any limitations on national treatment for this mode either.
Under the FTA with Malaysia, however, India caps foreign equity at 51 per cent. It requires prior
approval from the Foreign Investment Promotion Board (FIPB) if the foreign investor already
has a prior collaboration in the same service sector in India. India also denies national treatment
to Malaysian service suppliers.
4
Under the FTA with Mauritius, India requires service suppliers to obtain prior government
approval for market access. However, India provides a carve-out for NRIs and PIOs, though it
has restrictions on repatriation.
India subjects service suppliers from Mauritius, Australia, the UAE, and EFTA to registration with
the CoA under a reciprocity scheme in order to grant them national treatment for supplying
services through Modes 1, 2, and 3. India does not explicitly impose this requirement in its FTAs
with Korea, Japan, and Singapore.
For Mode 4, India extends market access and national treatment to service suppliers from
Korea, Japan, and Malaysia according to the horizontal commitments specified in the schedule
of commitments in the respective FTAs. In contrast, India restricts market access and national
treatment in its FTAs with Mauritius, Australia, the UAE, EFTA, and the UK to professionals
who act as consultants or designers for specific projects in India, provided they receive prior
permission from the central government. These professionals must also be recognised as
‘Architects’ under Indian law and must register with the relevant professional body under a
reciprocity scheme between India and their home country.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 40
2.7 Landscape Architectural Services and Urban Planning
Urban planning and landscape architectural
services are integral to addressing the rapid
urbanisation and complex challenges faced
by growing cities in India. While these
professions align with architecture, they
also function as independent disciplines. An
urban planner works to create and implement
plans for the development of cities,
towns, and other urban areas. Landscape
architects focus on designing open spaces,
incorporating elements such as plants, trees,
and landscapes (TAA, 1972, sec. 37(1)(b)(i)).
2.7.1 Legal and Regulatory
Framework for Professionals
Rendering Landscape Architectural
Services and Urban Planning
Urban planning in India functions within
a layered legal and regulatory framework,
shaped by constitutional provisions,
central legislation, and state-specific town
planning laws and municipal bylaws. The
73rd and 74th Constitutional Amendment
Acts of 1992 introduced the Eleventh and
Twelfth Schedules, which provide the
basis for decentralised planning by local
self-government institutions (Urban and
Regional Development Plans Formulation
and Implementation (URDPFI) Guidelines,
2014, 1). While the Eleventh Schedule
enumerates functions that may be devolved
to Panchayati Raj Institutions in rural areas,
such as rural housing, roads, drinking water,
and electrification, the Twelfth Schedule
assigns specific responsibilities to Urban
Local Bodies (Municipalities), such as urban
planning including town planning, regulation
of land use and construction of buildings,
slum improvement, and urban forestry
and environmental protection. Although
“landscape architecture” is not expressly
mentioned, its elements are reflected in
the Twelfth Schedule through the emphasis
on parks, gardens, playgrounds, and
environmental management.
This constitutional foundation is
operationalised through a web of statutory
laws and regulations. At the national level,
frameworks such as the Model Regional
and Town Planning and Development Law,
1985, the URDPFI Guidelines, 2014, influence
planning and development norms. Whereas,
States and Union Territories have enacted
their own Town and Country Planning Acts,
for example, the Delhi Development Act,
1957, the Uttar Pradesh Urban Planning and
Development Act, 1973, the Maharashtra
Regional and Town Planning Act, 1966 and the
Karnataka Town and Country Planning Act,
1961, to establish development authorities
and regulate master planning, zoning, and
land use.
Notably, India does not have a dedicated
law governing urban planners and landscape
architects. The CoA only regulates the
educational aspects of these professions.
Although TAA, 1972, under section 37(1)(b)
(i), defines a landscape architect, it does not
prohibit them from using the title or style
of an architect, nor does it contain specific
provisions governing their professional
practice. In the absence of statutory
regulation, professional bodies such as the
Institute of Town Planners India (ITPI) and
the Indian Society of Landscape Architects
(ISOLA) play some role in guiding the
profession.
Additionally, AICTE prescribes a model
curriculum for an undergraduate programme
in planning. ITPI recognises degrees in
planning by Indian and foreign universities,
while providing a mechanism for the
approval of courses on planning run by
various institutions, colleges, and universities,
to make students eligible to become an
Associate or Fellow members of ITPI. ITPI

India’s Services Sector: Insights on Regulatory Regime in Professional Services41
and ISOLA also provide ethical guidelines
and professional conduct for urban planners
and landscape architects, respectively.
2.7.2 Competencies of Professionals
to Render Landscape Architectural
Services and Urban Planning
Urban planning programs in India include
bachelor’s degrees, such as Bachelor of
Planning (B.Plan) or Bachelor of Technology
(B.Tech. Planning), and master’s degrees,
while landscape architecture is available
as a specialised master’s program (M.Arch
Landscape). The B.Arch curriculum,
mandated by the CoA, includes modules on
urban planning and landscape architecture
(COAMSAER, 2020, app. A). However, India
does not offer dedicated bachelor’s degrees
in landscape architecture, and entrance
requirements for these programs vary by
university. Entry into planning courses
is typically through standardised exams
like NATA and GATE; however, there is no
centralised entrance exam for landscape
architecture.
Professional bodies, such as the ITPI and
ISOLA, award membership to practitioners
based on their qualifications and experience.
These memberships allow urban planners
and landscape architects to practice based
on their educational credentials without
requiring additional licenses. While ITPI and
ISOLA provide recognition and guidance,
they do not have regulatory authority over
these professions.
The Town and Country Planning Organisation
(TCPO) functions as a technical arm of
the Ministry of Housing and Urban Affairs,
providing research, advisory, and capacity
support for urban and regional planning in
India. Urban planners in Town and Country
Planning Organisation (TCPO) for the central
government shall either hold a B.Plan or
a relevant post graduate degree from a
recognised university/ institute (in town or
city or urban or housing or country or rural
or infrastructure or regional or transport or
environmental planning) with three years’
experience in the field of urban or regional
planning in the central government or
state governments or union territories
or universities or recognised research
institutions or public sector undertakings or
semi-government or statutory or autonomous
organisations (Reforms in Urban Planning
Capacity in India 2021, annex 1).
Additionally, Annex 1 of the Reforms in Urban
Planning Capacity in India (NITI Aayog,
2021) also notes desirable qualification for
urban planners. A desirable qualification of
urban planners may include an “Associate
Membership” of the Institute of Town Planners,
India along with one-year experience in
Remote Sensing and Geographic Information
System Application in the Central Government
or State Governments or Union territories
or Universities or recognised Research
Institutions or Public Sector Undertakings
or Semi-Government or Autonomous or
Statutory Organisations.
As for the state governments, each has its
own recruitment rules for appointing urban
planners, and they generally follow the TCPO
recruitment rules as a model. For example, a
B. Plan / Master’s Degree in urban planning
with B.Arch/BE Civil/PG in Geography/
Economics/ Sociology) is required for entry
in Delhi’s T&CP Department.
2.7.3 Other Restrictions for
Professionals Rendering Landscape
Architectural Services and Urban
Planning
India does not have a specific regulatory
framework governing these professions,
and therefore, there are no specific barriers
to practicing these professions. Foreign
professionals can practice urban planning

India’s Services Sector: Insights on Regulatory Regime in Professional Services 42
in India by joining firms as planners or
establishing partnerships, similar to
architectural practices. However, they cannot
hold planning positions in government
organisations, which are reserved for Indian
citizens.
Box 10. India’s Commitment in Landscape Architectural Services and Urban Planning under GATS
and its FTAs
India has not committed this sub-sector under GATS.
India has not committed to landscape architectural services in its FTA with Singapore. In its FTAs
with Korea, Japan, Malaysia, Mauritius, Australia, the UAE, EFTA, and the UK, India fully liberalizes
market access and national treatment for the supply of these services through Modes 1 and 2,
allowing service suppliers and consumers from these countries to operate without barriers.
For Mode 3, India allows market access only through incorporation as a partnership firm consisting
of architects across all its FTAs. It does not impose any limitations on national treatment under this
mode. In its FTA with the UK, it has been specified that commercial presence can be established
through a sole proprietorship and a partnership firm constituted by architects. Additionally, for
services suppliers from the UK, national treatment for the supply of services through Modes 1, 2
and 3 that require use of the title and style of ‘Architect’ under applicable national law shall be
subject to registration with the relevant professional body under a scheme of reciprocity.
In its FTA with Malaysia, India caps foreign equity at 51 per cent. It requires prior approval from
the FIPB if the foreign investor has an existing collaboration in the same service sector. It also
denies national treatment to Malaysian service suppliers.
Under the FTA with Mauritius, India requires service suppliers to obtain prior government approval
to access the market and receive national treatment. However, it carves out an exception for NRIs
and PIOs, though it places restrictions on repatriation.
India subjects service suppliers from Mauritius, Australia, the UAE, and EFTA to registration with
the Council of Architecture under a reciprocity scheme in order to grant them national treatment
for supplying services through Modes 1, 2, and 3. In contrast, India does not explicitly impose this
requirement in its FTAs with Korea and Japan.
For Mode 4, India extends market access and national treatment to service suppliers from
Korea, Japan, and Malaysia according to the horizontal commitments specified in the schedule
of commitments in the respective FTAs. In contrast, India restricts market access and national
treatment in its FTAs with Mauritius, Australia, the UAE, EFTA, and the UK to professionals who act
as consultants or designers for specific projects in India, provided they receive prior permission
from the central government. These professionals must also be recognised as ‘Architects’ under
Indian law and must register with the relevant professional body under a reciprocity scheme
between India and their home country.
Under the India-Singapore FTA, India imposes no limitations on market access and national
treatment for the supply of urban planning services through Modes 1 and 2, subject to compliance
with domestic regulations. For Mode 3, it permits market access only through incorporation
as a partnership firm and requires compliance with conditions set by the CoA and/or other
designated regulatory agencies. National treatment is also subject to fulfilling these regulatory
requirements. For Mode 4, India limits market access and national treatment to employees of
juridical persons and independent professionals who have contracts with final clients in India,
subject to registration with the CoA and/or other designated regulatory agencies, and entry and
stay durations as outlined in the horizontal commitments.

India’s Services Sector: Insights on Regulatory Regime in Professional Services43
2.8 Engineering Services
Engineering is a vast field of practice
encompassing diverse disciplines, with active
participation from both public and private
sector enterprises. It includes multinational
companies, domestic players and regional
players in the organised sector and
numerous small players in the unorganised
sector.  Between 2015 and 2022, engineering
remained the dominant technical education
domain, accounting for 67.2% of all technical
degrees (India Employment Report 2024:
Youth employment, education and skills, 115).
Furthermore, engineering is a significant
employment generator, particularly in civil
engineering within the construction industry,
as highlighted in the India Employment
Report 2024 by the ILO.
The ten-year period from 2014–15 to 2024–25
saw a significant growth in the exports and
imports of engineering services, according
to RBI data on invisibles (Figure 7). Exports
rose from US$1,769 million to US$13,766
million, registering a CAGR of 22.8%. During
the same period, imports increased from
US$1,592 million to US$1,734 million, with a
CAGR of 0.9%. This data demonstrates that
engineering services significantly contribute
to the growth of India’s professional services
sector.
Figure 7. Trade in Engineering Services
Source: RBI data on invisibles
2.8.1 Legal and Regulatory
Framework for Professionals
Rendering Engineering Services
India currently does not have a comprehensive
regulatory framework that governs the
profession of engineering, in a manner similar
to laws governing architecture or medicine.
The executive branch of the government,
along with certain professional bodies,
has made several attempts to introduce
a legislative framework by proposing the
enactment of an Engineers Bill. However,
the bill is yet to be enacted by the Indian
Parliament, and as a result the profession of
engineering remains largely unregulated.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 44
Although the profession itself remains
unregulated, the education of engineers falls
under the purview of the AICTE Act, 1987, and
is regulated by the AICTE. The AICTE also
enforces the All India Council for Technical
Education (Constitution and Functions of
National Board of Accreditation) Regulations,
2005, to oversee quality standards. The AICTE
approves all bachelor’s degree programmes
in engineering, while statutory universities
and deemed universities approved by
the University Grants Commission (UGC)
award these degrees. Additionally, the UGC,
through the UGC (Recognition and Grant
of Equivalence to Qualifications Obtained
from Foreign Educational Institutions)
Regulations, 2025, provides a mechanism for
granting equivalence to foreign engineering
degrees, enabling foreign-trained engineers
to practice in the Indian market.
Engineers may not have a statutory body
governing them in India. However, the
industry has formed professional bodies
to help set standards and guide the
professionals. Membership of such bodies is
generally recognised and acknowledged as a
mark of quality and experience.
2.8.2 Competencies of professionals
to render engineering services
In India, engineers are not required to
obtain a license to practise; however, they
must possess the requisite educational
qualifications and technical expertise,
particularly in specialized branches such as
civil engineering and other construction-
related fields. For construction and
infrastructure-related projects, the National
Building Construction Standards 2026
(NBCS 2026), applies and all civil engineers
and other professionals involved in such
projects must comply with the provisions of
the NBCS 2026.
Admission into engineering programmes
typically occurs through entrance exams,
some conducted by individual universities
and others through centralised testing at
national or state levels. For example, JEE
Main and Advanced are the gateways to
Bachelor of Engineering (B.E.) and Bachelor
of Technology (B.Tech) programmes at
IITs, NITs, and a few other top institutions.
For postgraduate programmes like M.E. or
M.Tech, candidates appear for the GATE
examination. States also conduct their own
exams, such as the West Bengal JEE (WBJEE)
and Karnataka’s COMEDK UGET.
At the undergraduate level, students usually
pursue either a B.E. or a B.Tech degree. Once
they complete their degree from an AICTE-
approved institution, ideally one accredited
by the National Board of Accreditation (NBA),
they are free to practice as professional
engineers.
Moreover, India is also a signatory to
international engineering agreements such
as the Washington Accord, which are further
detailed in Box. 11.

India’s Services Sector: Insights on Regulatory Regime in Professional Services45
Box 11. List of International Engineering Agreements
To have common qualification standards in engineering services, there are three international
accords and four international agreements governing the mutual recognition of engineering
qualifications and professional competence.
Accords
Is India a party/
member?
Highlights
1. The
Washington
Accord (1989)
Yes
• The Washington Accord is an
international agreement among
bodies responsible for accrediting
engineering degree programmes.
It recognises the equivalency of
programmes accredited by the
signatory bodies.
• There are currently 25 full signatories
and seven provisional signatories of
the Washington Accord.
• The National Board of Accreditation
(NBA), India, became a full signatory
of the Washington Accord in 2014.
• The NBA-accredited programmes
offered by the Tier-1 Institutions in
India are eligible for recognition by
other signatories of the Washington
Accord.
2. The Sydney
Accord (2001)
No
• The Sydney Accord is a global
agreement between organisations
that accredit engineering degree
programmes. It focuses on
recognising the qualifications
needed to become an Engineering
Technologist.
• There are currently 11 full signatories
and two provisional signatories of
the Sydney Accord.
3. The Dublin
Accord (2002)

No
• The Dublin Accord is an
international agreement between
bodies responsible for accrediting
engineering technology programmes,
focusing on mutually recognising
qualifications necessary for obtaining
titles as Engineering Technicians.
• There are currently eight full
signatories and one provisional and
conditional signatory of the Dublin
Accord.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 46
The three accords primarily address the mutual recognition of tertiary-level engineering
qualifications (Goyal & Mukherjee, 2013). Complementing these are four international agreements
that focus on competence-based recognition at the practicing engineer level. These agreements
emphasize the assessment of an individual’s professional competency against internationally
benchmarked standards. The four agreements are:
(i) APEC Engineer Agreement (APECEA) – 1999
(ii) International Professional Engineers Agreement (IPEA) – 2001
(iii) International Engineering Technologist Agreement (IETA) – 2003
(iv) Agreement for International Engineering Technicians (AIET) – 2015
Of these four agreements, India is only a member of the IPEA (formerly the Engineers Mobility
Forum). Under this arrangement, the Institution of Engineers (India) is empowered to establish
and maintain the India section of the International Professional Engineers (IntPE) Register.
The underlying principle of these accords and agreements is that an engineer or technologist
recognised in one member country as meeting international competency standards should only
undergo minimal additional assessment, primarily for local knowledge, before being granted
registration in another member country.
(Source: International Engineering Alliance)
2.8.3 Other Restrictions for
Professionals Rendering Engineering
Services
The engineering sector in India remains one
of the most flexible and globally accessible
segments of the economy. With no rigid
regulatory frameworks governing the
profession, the sector has remained open
to international participation while allowing
Indian engineers to seek opportunities
abroad with relative ease. Today, India
permits 100% FDI in engineering services,
effectively granting full market access to
foreign entities.
This openness is the result of gradual
liberalisation. In the early decades after
independence, India had nationalised much
of its industrial base, including engineering-
related sectors. The government began
delicensing the engineering industry in
the 1980s, a process that accelerated with
the economic reforms of 1991. By 2002,
the government fully opened the sector to
100% FDI, marking a significant shift toward
a more investment-friendly regime (Singha
and Gayithri).
Entities providing engineering or integrated
engineering services can set up operations
in India through various business structures,
including sole proprietorships, partnerships,
limited liability partnerships (LLPs), or
incorporated companies. Additionally, there
are no fees or advertising restrictions for
professionals rendering these services.

India’s Services Sector: Insights on Regulatory Regime in Professional Services47
Box 12. India’s Commitment in Engineering Services under GATS and its FTAs
India has committed to engineering services under the GATS. It restricts market access and
national treatment entirely for the supply of these services through Modes 1 and 2. For Mode 3,
India permits market access to foreign service suppliers to operate only through incorporation
and imposes a foreign equity cap of 51 per cent. However, it does not place any limitation on
national treatment under this mode. For Mode 4, both market access and national treatment are
subject to the horizontal commitments made under the GATS.
In its FTAs with Korea, Japan, Mauritius, Australia, the UAE, EFTA, and the UK, India has not
imposed any limitations on market access or national treatment for the supply of engineering
services through Modes 1, 2, and 3. For Mode 4, market access and national treatment are subject
to the horizontal commitments set out in the respective FTAs.
Under its FTA with Singapore, India allows full market access and national treatment for engineering
services supplied through Modes 1 and 2. For Mode 3, India allows market access only through
incorporation within India, but does not impose any limitation on national treatment. For Mode
4, India applies limitations based on the horizontal commitments in the India-Singapore FTA.
These apply to independent professionals and employees of juridical persons in highly skilled or
managerial roles, subject to a contract with a final client in India and fulfilment of qualification
and licensing requirements. In the case of juridical persons, India also imposes a ceiling of 5% of
the total workforce on a project.
In its FTA with Malaysia, India does not place any limitations on market access or national
treatment for engineering services supplied through Modes 1 and 2. For Mode 3, India allows
market access only through incorporation, imposes a 51 per cent foreign equity ceiling, and
requires prior approval from the FIPB if the foreign investor has an existing collaboration in that
specific service sector in India. India does not extend national treatment to Malaysian service
suppliers under this mode. For Mode 4, India regulates market access and national treatment
according to the horizontal commitments in the India-Malaysia FTA.
2.9 Healthcare Services and Allied Healthcare Services
Healthcare and allied healthcare
professionals in India include practitioners
across the fields of medicine, dentistry,
AYUSH, veterinary, nursing, midwifery,
physiotherapy, and paramedical care.
According to the World Health Organisation
(WHO), a “health practitioner” encompasses
all health professionals, health associate
professionals, including community health
workers, health care assistants, and personal
care workers in health services (allopathy
as well as traditional, complementary and
integrative medicine) as defined in the
International Standard Classification of
Occupations (ISCO-08), and new or health
practitioners yet to fall under an official
classification but who are directly involved
in patient diagnostics or care (WHO Health
Practitioner Regulation: Design, Reform and
Implementation Guidance).
Exports of health services from India have
experienced a significant growth trajectory
over the past decade. The data in Figure 8
shows exports to have surged from US$270
million in 2014-15 to US$723 million in 2024-
25. This growth was not always linear; after
a period of stability, exports saw a dip in
2020-21 before accelerating sharply in the
following years. Imports rose from US$22

India’s Services Sector: Insights on Regulatory Regime in Professional Services 48
million in 2014-15 to US$97 million in 2024-25.
This growth also had periods of fluctuation,
but the overall trend points to an expanding
engagement in the health services trade.
Figure 8. Trade in Health Services
Source: RBI data on invisibles
2.9.1 Medical Services
(i) Legal and Regulatory Framework
for Professionals Rendering Medical
Services and AYUSH (Ayurveda, Yoga
and Naturopathy, Unani, Siddha, and
Homoeopathy, including Sowa-rigpa)
The National Medical Commission Act,
2019 (NMC Act) regulates the practice
of allopathic medicine in India through a
structured legal framework. It mandates
the registration of medical practitioners
to prevent unqualified individuals from
practicing medicine (NMC Act, 2019, sec.
34(1)); recognises medical qualifications
listed in its schedules (NMC Act, 2019,
sec. 35), and prescribes uniform standards
for medical education and professional
conduct (NMC Act, 2019, sec. 10(a)). In
2020, the National Medical Commission
(NMC) was established as the apex
regulatory authority for medical education
and practice in India (NMC Act, 2019, sec.
3), replacing the erstwhile Medical Council
of India, following the repeal of the Indian
Medical Council Act, 1956.
The NMC functions through four
autonomous boards: the Undergraduate
Medical Education Board; the Postgraduate
Medical Education Board; the Medical
Assessment and Rating Board; and the
Ethics and Medical Registration Board
(NMC Act, 2019, sec. 16). These boards
oversee medical education at the levels
of undergraduate, postgraduate and
super-specialty training, institutional
accreditation, and professional conduct,
respectively (NMC Act, 2019, sec. 24, 25, 26
and 27). The Ethics and Medical Registration
Board maintains the National Register
of licensed medical practitioners (NMC
Act, 2019, sec. 31(1)), while State Medical
Councils constituted under section 30 are
responsible for maintaining and updating
the State Registers and transmitting them
to the national board in the prescribed
format (NMC Act, 2019, sec. 31(6)).
The NMC also sets standards for medical
education and conducts key national
examinations, including the National
Eligibility-cum-Entrance Test (NEET) and
the proposed National Exit Test (NExT)
(NMC Act, 2019, secs. 10(1)(a), 14, 15). Its
regulatory mandate is further detailed in
a set of subordinate regulations, including
the National Exit Test Regulations,

India’s Services Sector: Insights on Regulatory Regime in Professional Services49
2023; Postgraduate Medical Education
Regulations, 2023; Recognition of
Medical Qualification Regulations, 2023;
Maintenance of Standards of Medical
Education Regulation, 2023; Registered
Medical Practitioner (Professional Conduct)
Regulations, 2023; Registration of Medical
Practitioners and License to Practice
Medicine Regulations, 2023; Foreign
Medical Graduate Licentiate Regulations,
2021; and Telemedicine Practice Guidelines,
2020.
As per the Constitution of India, Public
Health is a subject under the State List
(Constitution of India, 1950, VII Schedule,
List II, Entry 6), which gives state
legislatures primary authority over health-
related governance. However, Medical
Education and the Medical Profession fall
under the Concurrent List (Constitution of
India, 1950, Art. 246, VII Schedule, List III,
Entry 25), empowering both the central
and state governments to enact laws in
these domains.
AYUSH
The National Commission for Indian System
of Medicine Act (NCISM Act, 2020),
provides the statutory framework for
regulating the education and professional
practice of Indian medical systems such
as Ashtang Ayurveda, Unani, Siddha and
Sowa-Rigpa (NCISM Act, 2020, sec. 2(h)).
The Act mandates the registration of
practitioners in either the National or State
Register (NCISM Act, 2020, sec. 34(1)(a)).
It establishes the National Commission for
Indian System of Medicine (NCISM) as the
apex regulatory authority for education,
practice, and registration of professionals
across these disciplines (NCISM Act, 2020,
sec. 3), thereby replacing the erstwhile
Central Council of Indian Medicine.
Additionally, the Act repeals the Indian
Medicine Central Council Act, 1970 (NCISM
Act, 2020, sec.58(1)).
The NCISM operates through four
autonomous boards: i) the Board of
Ayurveda, ii) the Board of Unani, Siddha and
Sowa-Rigpa, iii) the Medical Assessment
and Rating Board for Indian System of
Medicine and iv) Board of Ethics and
Registration for Indian System of Medicine
(NCISM Act, 2020, sec. 18(1)). These bodies
determine the standards of education at
the levels of undergraduate, postgraduate
and super-specialty. They further, develop
curriculums, frame guidelines for setting up
concerned medical institutions, facilitate
training of faculty, grant recognition
to medical qualifications, and regulate
professional conduct in accordance with
the regulations made under the NCISM Act
(NCISM Act, 2020, sec. 26(1)(a), (g), (i),
sec. 27(1)(b)).
The Ethics and Medical Registration Board
maintains the National Register of licensed
medical practitioners (NCISM Act, 2020,
sec. 27(1)(a)), while State Medical Councils
constituted under section 31 are responsible
for maintaining and updating the State
Registers (NCISM Act, 2020, sec. 32(5)). In
addition, the NCISM conducts NEET, NeXT,
and Post-Graduate National Entrance Test
(NCISM Act, 2020, sec. 14, 15, 16).
The Practitioners of Indian Medicine
(Standards of Professional Conduct,
Etiquette and Code of Ethics) Regulations,
1982 and the Indian Medicine Central Council
(Minimum Standards of Education in Indian
Medicine) Amendment Regulations, 2019,
which establishes professional conduct
and educational standards, also govern the
practitioners of Indian system of medicine.
Homoeopathy is governed by a separate
law, the National Commission for
Homoeopathy Act, 2020 (NCH, 2020). This
Act mirrors the exact same structure of the
NCISM framework, creating the National
Commission for Homoeopathy (NCH) as
the apex regulatory authority for the field

India’s Services Sector: Insights on Regulatory Regime in Professional Services 50
(NCHA, 2020, sec. 3). The NCHA repealed
the erstwhile Homoeopathy Central Council
Act, 1973 and dissolved the Central Council
of Homoeopathy (NCHA, 2020, sec. 58(1)).
(ii) Competencies of Professionals to
Render Medical Services and AYUSH
Medical education in India is regulated
through the NMC Act, 2019 and its related
regulations. To enroll in the Bachelor of
Medicine and Bachelor of Surgery (MBBS)
program, candidates must have completed
the 10+2 examination with qualification in
specified subjects and qualify the NEET
(NMC Act, 2019, sec. 14). The MBBS degree
is awarded upon completing the final MBBS
examination and the successful completion
of a one-year compulsory internship
mandated by the NMC (Compulsory
Rotating Medical Internship) Regulations,
2021 (NMC, NExT Regulations, 2023, Reg. 4).
This regulation of 2021 outlines the structure,
duration, and clinical training standards
required in the compulsory internship. A
Registered Medical Practitioner (RMP) is
further required to participate in Continuing
Professional Development (CPD) programs
regularly, accumulating a minimum of
30 credit hours every five-year cycle to
maintain professional competence (NMC
Registered Medical Practitioner (Professional
Conduct) Regulations, 2023, reg. 4). The
list of recognised medical qualifications in
India is maintained by the Undergraduate
Medical Education Board (UGMEB) for
undergraduate qualifications and by the
Postgraduate Medical Education Board
(PGMEB) for postgraduate qualifications
(NMC (Recognition of Medical Qualification)
Regulations, 2023, reg. 5). In addition,
to enhance the standards and quality of
medical education, the NMC has enacted
the Maintenance of Standards of Medical
Education Regulations, 2023 (MSMER).
To ensure uniform standards of competence
among medical graduates, the NMC Act,
2019 has proposed the NExT examination
and has notified the National Exit Test
Regulations, 2023, to operationalize and
govern the conduct of NExT. Although
not yet operational, it stipulates that
NExT will serve as a common final-year
undergraduate examination for granting a
license to practice and enroll in the State
or National Medical Register. The NMC is to
conduct this exam through a designated
authority, and it must be made operational
within three years from the commencement
of the Act, as notified by the central
government. Additionally, foreign medical
graduates must also qualify NExT to obtain
registration and licensure to practice in
India (NMC Act, 2019, sec. 15).
Once NExT becomes operational, only
individuals who qualify the exam will be
granted a license to practice medicine in
India and have their name and qualifications
entered in the National or State Medical
Register (NMC Act, 2019, sec. 33(1)).
Further, any individual who has obtained a
foreign medical degree and is recognised
as a medical practitioner in that country
must also qualify NExT to be eligible for
enrolment in India (NMC Act, 2019, sec.
33(2)). Any person who is not enrolled in
either the State or National Register will
not be permitted to practice medicine as a
qualified medical practitioner in India (NMC
Act, 2019, sec. 34(1)).
Foreign medical graduates (FMGs),
Indian citizens or OCI who have earned
their medical degrees abroad must meet
specific requirements under the NMC Act,
2019, and the Foreign Medical Graduate
Licentiate (FMGL) Regulations, 2021, to
be eligible to practice medicine in India.
These requirements include completing
a minimum 54-month medical program
and a 12-month internship in the same

India’s Services Sector: Insights on Regulatory Regime in Professional Services51
institution abroad, receiving instruction
in English, registering with the relevant
foreign medical authority, and completing
a 12-month supervised internship in India
(FMGL Regulations, 2021, reg. 4). The
NMC has also clarified, through its public
notices dated 07.12.2023, 19.06.2024 and
18.03.2026, that FMGs who undertook
online study during their penultimate or final
years must either sufficiently compensate
such study through physical attendance
at the foreign institution or undergo the
prescribed clerkship in India before being
considered eligible for registration. They
must also clear NExT, which is set to replace
the Foreign Medical Graduate Examination
(FMGE), as a precondition for enrolment in
India (NMC Act, 2019, s. 15(4)). Only after
fulfilling these conditions can FMGs be
enrolled in the National or State Medical
Register and legally practice in India NMC
(NExT) Regulations, 2023, reg. 3(3)).
While the NMC Act allows for temporary
registration of foreign citizens for a limited
period (NMC Act, 2019, s. 34(1)), the FMGL
Regulations explicitly prohibit practice
by FMGs without permanent registration
post-November 2021 (FMGL Regulations,
2021, reg. 3).
After successful completion of the MBBS
program, a candidate becomes eligible to
pursue postgraduate medical education. As
per section 15(5) of the NMC Act, admission
to postgraduate broad-specialty programs
(MD/MS/DNB) will be based on the NeXT,
once it becomes operational.
Postgraduate medical education is
regulated by the Postgraduate Medical
Education Board (PGMEB) under the
NMC and governed by the Post-Graduate
Medical Education Regulations, 2023, which
prescribe uniform standards for training,
curriculum, research, and assessment (NMC
Act, sec. 25).
Graduates who wish to specialize further
may pursue super-specialty courses such
as Doctorate of Medicine or Master of
Chirurgie (M.Ch.), for which admission is
granted through a national-level entrance
examination, currently NEET-SS. These
programs are designed to produce highly
skilled specialists in disciplines like cardiology,
neurology, surgical gastroenterology, etc. The
PGMEB, functioning under the supervision
of the NMC, regulates these courses in
accordance with the Post-Graduate Medical
Education Regulations, 2023 (PGMER)
(PGMER, reg 4.1).
AYUSH
Professionals practicing Indian systems
of medicine such as Ayurveda, Unani,
Siddha etc. require specific educational
qualifications including specialised
undergraduate and postgraduate degrees.
Admission to undergraduate programmes
such as, Bachelor of Ayurvedic Medicine
and Surgery (BAMS), Bachelor of Unani
Medicine and Surgery (BUMS), Bachelor
of Siddha Medicine and Surgery (BSMS),
Bachelor of Sowa-Rigpa Medicine and
Surgery (B.S.R.M.S) and Bachelor of
Homoeopathic Medicine and Surgery
(BHMS) requires candidates to complete
their 10+2 education with specified subjects
and qualify NEET, as per section 14 of both
the NCISM Act and the NCH Act.
The degrees are awarded upon successful
completion of the academic coursework
(usually 5 years) and a one-year
compulsory rotating internship (NCISM
(Minimum Standards of Undergraduate
Ayurvedic Education) Regulations, 2022
(reg 7), NCISM (Minimum Standards
of Undergraduate Unani Education)
Regulations, 2022 (reg 6), NCISM
(Minimum Standard of Undergraduate
Siddha Education) Regulations, 2022
(reg 7), NCISM (Minimum Standard of

India’s Services Sector: Insights on Regulatory Regime in Professional Services 52
Undergraduate Sowa-Rigpa Education)
Regulations, 2022 (reg. 5), and NCH
(National Examinations in Homeopathy)
Regulations, 2023, reg. 13(5)(a)). Upon
attaining a degree, graduates become
eligible for registration in their respective
State or National Register, maintained by
the Board of Ethics and Registration for
each system, thereby allowing them to
practice legally in India (NCISM Act, 2020,
sec. 34(1); NCH Act, 2020, sec. 34(1)).
To ensure uniform standards and competence,
the NeXT, is proposed to be adapted as
the final qualifying exam for licensure and
registration in the Indian systems of medicine
as well, including homeopathy. (NCISM Act,
sec. 15, NCH Act, sec. 15).
Graduates may pursue postgraduate
degrees such as MD/MS in Ayurveda, MD
in Unani/Siddha, or MD in Homoeopathy,
regulated by the PGMEB for Indian
Medicine and the PGMEB for Homoeopathy.
These Boards oversee curriculum, training,
assessment, and standards of education
(NCISM Act, sec. 18, NCH Act, sec. 18).
Admission to these postgraduate courses is
based on a common entrance examination
as mandated under section 16 of both the
NCISM Act and the NCH Act.
Registered practitioners across all AYUSH
disciplines are expected to undertake CPD
trainings to maintain and update their clinical
knowledge and skills. The Practitioners of
Indian Medicine (Standards of Professional
Conduct, Etiquette and Code of Ethics)
Regulations, 1982 governs the professional
conduct regulations of AYUSH practitioners.
All institutions offering AYUSH education
must adhere to the Indian Medicine Central
Council (Minimum Standards of Education in
Indian Medicine) Amendment Regulations,
2019, and the respective AYUSH regulations
thereunder.
Any person with a foreign medical
qualification must qualify NeXT to
obtain a license to practice Indian
systems of medicine and for enrollment
in state or national register (NCISM Act,
2020, sec. 15(4)). A foreign citizen duly
registered as a practitioner of Indian
systems of medicine in accordance with the
applicable laws of their home country may be
granted temporary registration to practice
in India, for a specified duration and under
the conditions prescribed by Indian laws and
regulations (NCISM Act, 2020, sec. 34(1)
proviso).
(iii) Other restrictions for professionals
rendering medical services
Entities providing medical in India can
set up clinical establishments through
various structures, including any person
or body of persons, whether incorporated
or not, such as, hospitals, maternity
homes, nursing homes, dispensary, clinics,
sanatorium, diagnostic labs, or similar
institutions offering services in any
recognised system of medicine (Clinical
Establishments (Registration and
Regulation) Act, 2010, sec. 2(c). All
establishments must register and comply
with relevant central and state regulations,
such as Clinical Establishments (Central
Government) Rules, 2012, including
biomedical waste and radiation safety rules
(Clinical Establishments Act, 2010, sec. 11).
Practitioners of allopathic medicine,
Indian medicine, and homoeopathy are
prohibited from advertising or soliciting
patients. Registered Medical Practitioners
must not endorse products or publicise
cases (NMC RMP (Professional Conduct)
Regulations, 2023, reg. 7, 10). Indian
medicine and homoeopathy practitioners
face similar restrictions on promotional
activities (Practitioners of Indian Medicine
(Standards of Professional Conduct,
Etiquette and Code of Ethics) Regulations,
1982, Reg. 24).

India’s Services Sector: Insights on Regulatory Regime in Professional Services53
2.9.2 Dental Services
(i) Legal and Regulatory Framework for
Professionals Rendering Dental Services
Dentistry in India is regulated under the
newly enacted National Dental Commission
Act, 2023 (NDC Act), which repealed the
Dentists Act, 1948 and abolished the Dental
Council of India (DCI) w.e.f. 19.03.2026 (NDC
Act, 2023, sec.58). The Act establishes the
National Dental Commission (NDC) as the
apex regulatory authority for overseeing
dental education and professional practice
across the nation (NDC Act, 2023, sec.3).
Additionally, it provides for the constitution
of State Dental Councils to implement
regulations at the state level (NDC Act,
2023, sec.29). The regulatory framework
under the NDC Act is further supplemented
by the National Dental Commission Rules,
2024.
Dental practitioners in India are further
regulated by legacy regulations such as
the Dental Council of India Screening Test
Regulations, 2009, which govern screening
tests for foreign-qualified dentists; the
Dental Council of India (Code of Ethics)
Regulations, 2014, which establish ethical
standards for dental practice; the Dental
Council of India (BDS Course) Regulations,
2017, which outline the curriculum and
standards for the BDS course; and the Indian
Dental Association Code of Ethics, 2014,
which provides professional guidelines for
its members (NDC).
The NDC Act provides for the
establishment of autonomous boards to
perform key functions under the Act. The
Undergraduate Dental Education Board
and the Postgraduate Dental Education
Board oversee matters of dental education
including standards of education,
curriculum, recognition of qualifications
etc. (NDC Act, 2023, sec. 24). The Dental
Assessment and Review Board evaluates
dental institutions to ensure compliance
with quality and regulatory standards
(NDC Act, 2023. sec.25). For licensing
and registration, the Ethics and Dental
Registration Board maintains the National
Register (NDC Act, sec. 26), while the State
Dental Councils manage the State Registers
(NDC Act, sec. 29).
In addition to statutory bodies, the
Indian Dental Association (IDA) serves
as a prominent professional Organisation
representing dental practitioners across
India. The IDA plays an advisory role by
issuing professional guidelines such as the
IDA Code of Ethics (2014) and promoting
standards in dental practice, education,
and public oral health through advocacy
and continuing education initiatives (IDA).
(ii) Competencies of professionals to
render dental services
Dental education in India includes the
undergraduate course, Bachelor of Dental
Surgery (BDS), which spans five years,
including one year of compulsory rotatory
internship. Eligibility for admission to
this course requires completion of 10+2
education with Physics, Chemistry, Biology,
and English, along with qualifying the
NEET-UG, which serves as the single-
window entrance exam for all dental
colleges across India, whether government,
private, or deemed universities (NDC Act,
2023, sec.14(1)).
Postgraduate dental education is offered
through the Master of Dental Surgery
(MDS) program, which is a three-year
specialisation degree in disciplines such as
oral surgery, orthodontics, prosthodontics,
periodontology, and others. Admission to
the MDS program requires candidates to
qualify NEET-MDS. While some institutions
may conduct additional entrance exams
like the Institute of National Importance
Combined Entrance Test (INI CET),

India’s Services Sector: Insights on Regulatory Regime in Professional Services 54
NEET-UG and NEET-MDS remain the
primary gateways to becoming dental
practitioners in India. The National Exit
Test (Dental) (NeXT Dental) is slated to
replace NEET-MDS from 2026 onwards, as
the basis for admission to postgraduate
dental education in India (NDC Act, 2023,
sec.15). On completion of the educational
requirements, professionals must be
registered with the National or State
Register to be eligible to practice dentistry
in India.
Furthermore, foreign citizens seeking
to practice dentistry in India must also
register in either the State Register or
the National Register as per the NDC Act,
2023 (NDC Act, s. 31, s. 32). The Act also
allows a foreign citizen, registered as a
dentist in their home country, to apply
for a temporary registration in India for a
specified period and manner, as outlined
by relevant regulations (NDC Act, s. 32(1)).
For Indian citizens/ OCI/PIO possessing
a primary dental qualification or a
postgraduate diploma awarded by any
dental institution outside India, it is
mandatory to qualify through the Foreign
Dental Graduate Screening Test. This
examination is conducted by the National
Board of Examinations in Medical Sciences
(NBEMS).
(iii) Other Restrictions for Professionals
Rendering Dental Services
The legal forms of establishments
permissible for medical services under the
Clinical Establishments Act, 2010, whether
incorporated or unincorporated, are equally
applicable to dental services. Regardless
of its legal structure, every dental
establishment is mandated to register and
comply with the requirements stipulated
by the Clinical Establishments (Registration
and Regulation) Act, 2010; the Clinical
Establishments (Central Government)
Rules, 2012; and all relevant State and
Union Territory rules and notifications
(Clinical Establishments (Registration and
Regulation) Act, 2010, s. 11).
Dental practitioners may advertise ethically,
avoiding false claims, inducements, or
surrogate advertising. They must not
solicit patients through agents, endorse
commercial products, or publish unverified
opinions in lay media. All publicity must
uphold the dignity and welfare of patients
(Revised Dentists (Code of Ethics)
Regulations, 2014, Reg. 8.1).
Box 13. India’s Commitment in Medical and Dental Services under GATS and its FTAs
India has not committed to medical and dental services under GATS.
In its FTAs with Korea, Japan, Singapore, Malaysia, Mauritius, Australia, the UAE, EFTA, and the
UK, India does not place any limitation on market access for the supply of medical and dental
services through Mode 1 for the supply of services on a provider-to-provider basis, such that
the transaction is between established medical institutions covering areas of second opinion
to help in the diagnosis of cases or in the field of research. Further, India does not place any
limitation on national treatment in its FTAs with Korea, Japan, Singapore, Malaysia, Australia,
and the UK for the supply of services through this mode of supply. However, in its FTAs with
Mauritius, the UAE, and EFTA, the limitation on national treatment is identical to the limitations
on market access in these FTAs.
India has not placed any limitation on market access and national treatment on the supply of
services through Mode 2 in all its FTAs.

India’s Services Sector: Insights on Regulatory Regime in Professional Services55
In its FTAs with Korea and Japan, market access for the supply of services through Mode 3 is
subject to the incorporation requirement with a foreign equity ceiling of 74 per cent, subject to
the condition that the latest technology for treatment will be brought in. In its FTA with Korea,
national treatment is subject to the condition that publicly funded services may be available only
to Indian citizens or may be supplied at differential prices to persons other than Indian citizens.
Notably, India has completely restricted national treatment for the supply of services through this
mode in its FTA with Japan.
In its FTA with Singapore, market access for the supply of services through Mode 3 is subject to
incorporation in India and subject to the condition that the latest technology for treatment will
be brought in. Also, publicly funded services may be available only to Indian citizens or may be
supplied at differential prices to persons other than Indian citizens. National treatment is subject
to the condition that publicly funded services may be available only to Indian citizens or may be
supplied at differential prices to persons other than Indian citizens.
In its FTA with Malaysia, market access for the supply of services through Mode 3 is only through
incorporation with a foreign equity ceiling of 51 per cent subject to the condition that the latest
technology for treatment will be brought in and subject to the condition that in the case of
foreign investors having prior collaboration in that specific service sector in India, FIPB approval
would be required. India completely restricts national treatment for Malaysian service suppliers.
In its FTA with Mauritius, Australia, the UAE, and EFTA, market access for the supply of services
through Mode 3 is only through incorporation in India and subject to the condition that the
latest technology for treatment will be brought in, as provided in the national treatment column.
However, India does not place an incorporation requirement in its FTA with the UK. It allows
complete market access, subject to the condition that the latest technology for treatment will be
brought in.
India places identical limitations on national treatment in its FTAs with Mauritius, Australia,
and the UAE. It is subject to the condition that Professionals qualified outside India can
practice medicine for charitable purposes and dentistry for teaching and research purposes,
subject to permissions from relevant authorities under the applicable domestic laws.
Publicly funded services will be available only to Indian citizens or will be supplied at differential
prices to persons other than Indian citizens. However, India does not place any limitation on
national treatment in its FTA with EFTA and the UK for this mode of supply.
For Mode 4, market access and national treatment are subject to commitments made in the
horizontal section for the categories of service suppliers specified in India’s schedule of
commitment in all its FTAs, who are involved in charitable purposes, and subject to permissions
from relevant authorities.
2.9.3 Veterinary Service
Veterinary practitioners play a pivotal role
in safeguarding animal health, public safety,
food safety and in supporting the agrarian
economy. Veterinary training and practice
including the deployment of veterinary
doctors and para-veterinary staff falls
under the State list. Therefore, they are
managed individually by the respective
state governments based on local needs and
infrastructure (Constitution of India, 1950,
Entry 15, List II, Seventh Schedule). According
to the UN CPC classification, veterinary

India’s Services Sector: Insights on Regulatory Regime in Professional Services 56
services encompass animal and veterinary
hospital and non-hospital medical, surgical,
and dental services delivered to animals,
including but not limited to pet animals (UN
CPC classification, Provisional-Code 9320).
(i) Legal and Regulatory Framework for
Professionals Rendering Veterinary Services
The Indian Veterinary Council Act, 1984
(IVC Act) governs the practice of veterinary
medicine in India through a comprehensive
regulatory framework. The Act prohibits
unqualified individuals from offering
veterinary services and mandates the
registration of veterinary practitioners (IVC
Act, 1984, sec. 30). The Veterinary Council
of India (VCI), established under section 3
of the Act, serves as the statutory authority
responsible for maintaining the Indian
Veterinary Practitioners’ Register (IVC
Act, 1984, sec. 23), regulating veterinary
education (IVC Act, 1984, sec. 22),
overseeing professional conduct (IVC Act,
1984, sec. 31) and recognising veterinary
qualifications across the country (IVC Act,
1984, sec. 15, 16, 17).
Veterinary qualifications granted by
institutions in India that are listed in the First
Schedule of the IVC Act, are recognised
qualifications under the Act (IVC Act, sec.
15(1)). Institutions granting qualifications
not included in the First Schedule may
apply to the central government to have
such qualification recognised. On receiving
such an application, the central government
may, after consulting with the VCI, amend
the Schedule by notification in the official
gazette, to include such qualification and
specify the effective date of recognition
(IVC Act, sec. 15(2)). Similarly, foreign
veterinary qualifications included in the
Second Schedule and those recognised
through reciprocity agreements with
foreign regulatory authorities are valid to
enable practice in India (IVC Act, sec. 16(1)).
For veterinary qualifications obtained from
countries without a reciprocity scheme,
the central government, after consulting
the VCI, may recognise such qualifications
subject to specific conditions including
enrollment in the professional register of
the foreign country, limitation of practice to
affiliated institutions for specific purposes
like teaching or research, and restrictions
on duration of practice (IVC Act, 1984, sec.
17)). More recently, the Veterinary Council
of India (Foreign Veterinary Graduate
Registration) Rules, 2025 have further
clarified the pathway for foreign-qualified
veterinarians, requiring, among other
conditions, completion of the prescribed
foreign degree and internship, registration
with the competent foreign regulatory
body, passage of the Council’s test, and a
further internship in India before registration
is granted. This framework ensures that
veterinary practitioners holding recognised
qualifications meet India’s professional
standards.
In addition to the VCI, the IVC Act also
provides for the establishment of State
Veterinary Councils (SVCs), which operate
as autonomous regulatory bodies (IVC Act,
1984, sec. 32). Each SVC maintains a State
Veterinary Register and is responsible
for registering practitioners within its
jurisdiction (IVC Act, 1984, sec. 44).
Beyond statutory bodies, professional
associations like the Indian Veterinary
Association (IVA) and the Indian
Association of Veterinary Pathologists
represent veterinarians nationally and
at state levels, focusing on discipline-
specific issues and providing continuing
development education.
(ii) Competencies of Professionals to
Render Veterinary Services
The veterinary education in India includes
the Bachelor of Veterinary Science and
Animal Husbandry program (B.V.Sc. &

India’s Services Sector: Insights on Regulatory Regime in Professional Services57
A.H.). This program is regulated under
the VCI Minimum Standards of Veterinary
Education (B.V.Sc. & A.H.) Regulations,
2016 and the VCI (Professional Conduct,
Etiquette and Code of Ethics) Regulations,
1992, framed in accordance with the
provisions of IVC Act, 1984.
To enroll in the B.V.Sc. & A.H. program,
students must complete the 10+2
examination with proficiency in Physics,
Chemistry, Biology, and English (VCI
Minimum Standards of Veterinary Education
Regulations, 2016, reg. 6(b)), and qualify
through a national entrance examination
such as NEET (VCI) or any competitive
entrance examination conducted by a
university or state government or VCI
(VCI Minimum Standards of Veterinary
Education Regulations, 2016, reg. 7(1)).
The B.V.Sc. & A.H. program spans 5.5
years, including a mandatory rotating
internship, and must be completed at a
recognised institution. Upon graduation,
individuals must register with the State
Veterinary Council to legally practice
(VCI Minimum Standards of Veterinary
Education Regulations, 2016, reg. 11, 12)).
This registration further enables entry
into the Indian Veterinary Practitioners’
Register maintained by the VCI (VCI
Act, 1984, sec. 24). Thus, only registered
individuals are legally permitted to practice
as veterinarians and to charge for their
professional services (IVC Act, 1984, s. 29).
Once registered, veterinary practitioners
are authorised to diagnose and treat animal
diseases, perform surgeries, issue health
and post-mortem certificates, provide
transport and fitness certifications, and
serve as expert witnesses in courts (IVC
Act, 1984, sec. 30). Presently, there is no
exit examination required for veterinary
practitioners to practice in India.
Foreign-qualified veterinarians are also
subject to a defined registration route under
the Veterinary Council of India (Foreign
Veterinary Graduate Registration) Rules,
2025. A foreign veterinary graduate may
be registered only if the candidate satisfies
the prescribed eligibility conditions,
including completion of a foreign veterinary
degree of at least 54 months, a 12-month
internship in the same foreign institution,
English-medium instruction, passing the
compulsory subjects specified in the VCI
Minimum Standards Regulations, 2016,
registration with the competent foreign
regulatory body, and successful passage
of the test conducted by the Council
or another institution specified by the
Central Government. The rules also require
completion of a further 12-month internship
in India before registration is granted,
subject to limited relaxation by the Central
Government in special circumstances.
While B.V.Sc. & A.H. degree is the
minimum requirement for registration
and practice, many professionals pursue
postgraduate education to specialise
further. Postgraduate veterinary education
is regulated by the Indian Council of
Agricultural Research (ICAR) through the
VCI and is offered at various veterinary
colleges across the country (ICAR).
(iii) Other Restrictions for Professionals
Rendering Veterinary Services
The legal forms of establishments
permissible for medical services under
the Clinical Establishments Act, 2010,
whether incorporated or unincorporated,
are also applicable to veterinary services.
Regardless of its chosen legal structure,
every medical establishment must ensure
registration and compliance with the
requirements of the Clinical Establishments
Act, 2010; the Clinical Establishments

India’s Services Sector: Insights on Regulatory Regime in Professional Services 58
(Central Government) Rules, 2012; and
relevant State and Union Territory rules and
notifications.
Veterinarians are barred from soliciting
clients through advertisements or allowing
their name/image in public promotions.
However, limited factual announcements
(e.g., change of practice or address) are
allowed. They must also avoid indirect
advertising via associated firms/ publicity
in lay media, except in professional journals.
(VCI (Standard of Professional Conduct,
Etiquette and Code of Ethics for Veterinary
Practitioners’ Regulations, 1992, reg. 7).
Box 14. India’s Commitment in Veterinary Services under GATS and its FTAs
India does not commit to veterinary services under GATS.
In its FTAs with Korea, Japan, Singapore, Malaysia, Australia, and the UAE, India does not impose
any limitations on market access or national treatment for the supply of services through Modes
1, 2, and 3. However, in its FTA with Malaysia, market access for the supply of services through
Mode 3 is also subject to the condition that, in the case of foreign investors who have prior
collaboration in that specific service sector in India, approval from FIPB would be required.
In its FTA with Mauritius and EFTA, India has not imposed any limitations on market access for the
supply of services through Modes 1 and 2. Market access for the supply of services through Mode
3 is subject to the limitations provided for in the national treatment column for Modes 1, 3, and
4. National treatment for Modes 1, 3, and 4 is subject to the condition that professionals qualified
outside India can: (i) engage in teaching, research and charitable purposes subject to permissions
from relevant authorities under the applicable domestic laws; and (ii) practice veterinary services
in India subject to registration with relevant professional body under a scheme of reciprocity.
In its FTA with the UK, India has not placed any limitation on market access and national treatment
for the supply of services through Modes 1, 2, and 3.
Market access and national treatment for the supply of services through Mode 4 is subject to
the horizontal commitments in all of India’s FTAs. Additional conditions for Mode 4 in FTAs with
Mauritius and EFTA are described in the paragraph above.
2.9.4 Services Provided by Nurses
and Midwives
Nursing and midwifery constitute one
of the largest segments of the health
workforce in India, spanning both public
and private healthcare systems. According
to the International Labour Organisation,
Department of Statistics (ILOSTAT), “nurses
and midwives represent about half of the
workers in human health and social work”
(ILOSTAT).
(i) Legal and Regulatory Framework
for Professionals Rendering Nursing and
Midwifery Services
Nursing and midwifery in India are regulated
under the National Nursing and Midwifery
Commission Act, 2023 (NNMC Act), which
repealed the Indian Nursing Council Act,
1947 and abolished the Indian Nursing
Council (NNMC Act, 2023, sec. 56). The
Act establishes the National Nursing and
Midwifery Commission (NNMC) (NNMC
Act, 2023, sec. 3) with autonomous boards
for education, assessment and rating,
and ethics and registration, to ensure
uniform standards across the profession
(NNMC Act, 2023, sec.11). It mandates the
creation of State Nursing and Midwifery
Commissions, tasked with registering

India’s Services Sector: Insights on Regulatory Regime in Professional Services59
professionals, regulating institutions, and
addressing misconduct (NNMC Act, 2023,
sec. 23, 24).
The Act defines a nurse and midwifery
professional as a person who has obtained
the required qualification and has acquired
the requisite licence to practice (NNMC
Act, 2023 sec. 2(j) and sec. 2(f)). Such
professionals should also be enrolled in
the National or State Register maintained
by the NNMC or State Council following
the completion of recognised educational
qualifications (NNMC Act, 2023 sec. 25).
The NNMC serves as the apex regulatory
body for nurses and midwives in India
and undertakes the following functions,
among others: (i) establish and maintain
a central registry of qualified nurses and
midwives; (ii) set standards for nursing
and midwifery education and practice; (iii)
regulate curricula and accredit educational
institutions; (iv) ensure adherence to ethical
standards and professional conduct; (v)
recognise foreign nursing and midwifery
qualifications for registration in India; and
(vi) supervise and coordinate activities of
State Nursing Councils (NNMC Act, 2023,
sec. 3(1)). State Nursing Councils, on the
other hand, are empowered to: (i) maintain
state-specific registers of nurses and
midwives; (ii) admit eligible candidates to
the register; (iii) investigate and adjudicate
cases of professional misconduct; (iv)
protect the rights and privileges of
registered professionals; and (v) manage
funds and resources allocated for nursing
regulation within the state (NNMC Act,
2023, sec. 23, 24).
In addition, the NNMC and State Councils
are empowered to enforce continuous
professional development and re-
registration requirements to maintain
competency and quality of care (NNMC
Act, 2023, sec.10(2)(d), sec. 24(2)(b)).
The Act also specifies provisions for the
recognition of qualifications, wherein
nursing and midwifery qualifications
granted by universities or institutions
within India may be recognised by the
Nursing and Midwifery Undergraduate and
Postgraduate Board (NNMC Act, 2023,
sec. 28), while qualifications granted by
institutions outside India fall under the
purview of the National Commission (NNMC
Act, 2023, sec. 29). Complementing the Act,
the NNMC Rules, 2024 and Indian Nursing
Council (Nurse Practitioner Midwifery
(NPM) Educator Program Curriculum)
Regulations, 2020 have also been enacted
to support the regulatory framework.
(ii) Competencies of Professionals to
Render Nursing and Midwifery Services
Undergraduate nursing education in India
primarily includes the Bachelor of Science
in Nursing (B.Sc. Nursing), a four-year
professional degree that includes practical
clinical training across disciplines such
as medical-surgical nursing, community
health nursing, pediatric nursing, and
obstetrics and gynecology. To be eligible
for the B.Sc. nursing program, candidates
must have completed their 10+2 education
with proficiency in Physics, Chemistry,
and Biology as core subjects. The
admissions are based on merit or entrance
examinations conducted by state or
national authorities such as the NEET UG or
institutional entrance tests. Presently, there
is no centralised “exit exam” mandated
for nursing and midwifery; however,
Section 10(2)(g) of the NNMC Act, 2023
states that the National Commission may
provide a mechanism, “either through final
year undergraduate exam or otherwise,
to ensure adequate competence” for
enrolment in the National or State Register
and for granting a license to practice. It
does not use the exact words “exit exam” in
the statute text, but it authorizes a national

India’s Services Sector: Insights on Regulatory Regime in Professional Services 60
competence mechanism for registration/
licensure.
Additionally, the Auxiliary Nurse Midwife
(ANM) and General Nursing and Midwifery
(GNM) programs serve as entry-level
diplomas for nursing and midwifery
professionals. The ANM is typically a 2-year
program, while the GNM spans 3 to 3.5
years, including clinical rotations. With
the establishment of the NNMC under
the NNMC Act, 2023, they serve as entry-
level diploma pathways for nursing and
midwifery professionals.
Candidates who qualify the B.Sc. Nursing
degree and have relevant clinical experience
may pursue postgraduate studies such as
the Master of Science in Nursing (M.Sc.
Nursing), a two-year specialisation-
based program. Here, specialisations
include areas such as psychiatric nursing,
community health nursing, and midwifery.
Admission to M.Sc. Nursing programs
are often determined through entrance
exams conducted by institutions or state
authorities.
To be eligible to practice nursing or midwifery
in India, an individual must: (i) complete an
accredited nursing or midwifery education
program as prescribed by the NNMC; (ii)
register with the State Nursing Council or the
NNMC by submitting proof of qualifications
and paying the prescribed fees; and (iii)
adhere to the code of professional conduct
and ethics laid down by the NNMC. Their
names must be entered in the national
or state register, conferring a license to
practice (NNMC Act, sec.  26). Foreign-
trained nurses and midwives, qualified and
registered in their home country, are eligible
for temporary registration in India (NNMC
Act, sec.27(1)(b)).
The INC published the draft “Indian Nursing
Council (ANM to GNM) Two-year Bridge
Program Regulations, 2024” and “Post
Basic Diploma in Cardiothoracic Specialty
Nursing - Residency Program Regulations,
2023”, which include criteria requiring
nurses from other countries to obtain an
equivalence certificate from the Council
prior to admission.
The Trained Nurses’ Association of
India, established in 1908, is a voluntary
Organisation established to promote
nursing education and practice, and to
protect the interests of nurses. Specifically
for midwifery, the Society of Midwives,
India (SOMI) serves as a national-level
professional Organisation for registered
midwives, working to strengthen midwifery
as a profession and enable its members
to provide high-quality care. SOMI is
also affiliated with the International
Confederation of Midwives.
(iii) Other Restrictions for Professionals
Rendering Nursing and Midwifery Services
The legal forms of establishments
permissible for medical services under the
Clinical Establishments Act, 2010, whether
incorporated or unincorporated, are also
applicable to nursing, and midwifery
services. There is no specific residency
requirement to practice nursing and
midwifery in India. Registered nurses and
midwives work across diverse settings,
including hospitals, obstetrics and
gynecology clinics, general health clinics,
birthing centres, and private residences
(Kumar & Rodney, 2014). In India, there is
no explicit legislation under the NNMC Act,
2023 or related rules and regulations that
prohibit nurses or midwives from advertising
their services. However, advertising by
nurses and midwives remains ethically
sensitive and may invite disciplinary action
if it undermines professional standards
or patient trust. Additionally, India has
undertaken initiatives to promote cross-
border mobility for nurses through Mutual

India’s Services Sector: Insights on Regulatory Regime in Professional Services61
Recognition Agreements (MRAs) and other
international trade agreements.
2.9.5 Physiotherapy and
Paramedical Services
Physiotherapy and Paramedicine in India
are categorised under the allied and
healthcare professions and governed by
the National Commission for Allied and
Healthcare Professions Act, 2021 (NCAHP
Act, 2021) (NCAHP Act, 2021, Preamble).
The principal regulatory body overseeing
allied and healthcare professions, including
physiotherapists and paramedics, is
the National Commission for Allied and
Healthcare Professions (NCAHP) (NCAHP
Act, 2021, sec.3).
The Act distinguishes between healthcare
professionals and allied health professionals,
and covers 56 Allied and Healthcare
Professions categorised under 10 broad
recognised categories (The Schedule,
NCAHP Act), with physiotherapists and
paramedics often falling under the latter.
Paramedical sciences focus on emergency
services and the diagnostic role within the
broader medical field. Professionals in this
domain are crucial for assisting doctors, often
during critical incidents, such as accidents or
emergencies, by providing immediate care
and stabilisation (Institute of Health Science).
(i) Legal and Regulatory Framework for
Professionals Rendering Physiotherapy
and Paramedical Services
Public health, including physiotherapy
and paramedicine, falls under the State
List (Entry 6) of the Seventh Schedule of
the Constitution of India, granting states
the authority to legislate on matters of
healthcare delivery. However, the NCAHP
Act, 2021, provides a unified regulatory
structure for physiotherapists and
paramedics.
The physiotherapy degree programmes,
such as the Bachelor of Physiotherapy
(BPT) and Master of Physiotherapy (MPT),
are primarily regulated through health-
sector bodies like the National Commission
for Allied and Healthcare Professions
(NCAHP) and are offered with approval
and affiliation from relevant state or health
sciences universities. The NCAHP Act
establishes State Allied and Healthcare
Councils responsible for maintaining state-
level registers of professionals, enforcing
compliance, and ensuring the delivery of
ethical and competent services (NCAHP
Act, sec.22). The Act also mandates the
establishment of Professional Councils
for each category of allied and healthcare
professionals, to oversee curriculum
standards, accreditation, and registration
(NCAHP Act, sec.10). NCAHP issues
curriculum handbooks that set national
standards for programme structure, career
pathways, nomenclature, duration and
other key academic requirements for allied
and healthcare programmes. By June
2026, the commission had released 17 such
curricula, each outlining these elements in
detail.
Further, the National Commission for Allied
and Healthcare Professions Rules, 2021
(NCAHP Rules, 2021) prescribe the process
and fee for entering a person’s name in the
register (NCAHP Rules, 2021, Rules 11–15),
as well as the manner in which a new allied
healthcare institution can be established
(NCAHP Rules, 2021, Rule 17).
Additionally, the Clinical Establishments
(Registration and Regulation) Act, 2010
and Clinical Establishments (Central
Government) Rules, 2012, mandate
registration of all healthcare facilities,
including those run by physiotherapists and
paramedics. It ensures such establishments
meet minimum standards for infrastructure,

India’s Services Sector: Insights on Regulatory Regime in Professional Services 62
equipment, and qualified personnel. While
it does not regulate individuals, it governs
the facilities where healthcare services are
provided.
Several bodies contribute to the governance
of physiotherapists in India, including the
National Council for Clinical Establishments
(under the Clinical Establishments
Registration and Regulation Act, 2010),
the Central Council of Physiotherapy, the
Indian Association of Physiotherapists,
various State Physiotherapists Councils,
the All-India Council for Physical Therapy,
and the Society of Indian Physiotherapists.
In the absence of a dedicated legislation
prior to the enactment of NCAHP Act,
the paramedical sector in India was
shaped by various professional bodies
and government-affiliated institutions.
Organisations such as the Indian Association
of Paramedical Sciences (IAPS) and the
Healthcare Sector Skill Council (HSSC)
under the National Skill Development
Corporation (NSDC) have contributed to
establishing skill standards and ethical
guidelines for paramedical training and
practice. Beyond the framework established
by the NCAHP Act, 2021, the governance
of paramedical professionals is also
influenced by various state paramedical
acts, rules, and regulations. From an ethical
perspective, medical deontology guides
the moral actions of paramedical staff and
medical activities, primarily to secure each
person’s well-being and protect individuals
from harm (Tseng & Wang, 2021).
The Indian Association of Physiotherapists
(IAP), though not a statutory body, has been
instrumental in formulating ethical codes
and facilitating continuing professional
development. However, section 11(b) of
the NCAHP Act, 2021, vests the power to
regulate professional conduct, the code of
ethics, and etiquette in the NCAHP.
(ii) Competencies of Professionals to Render
Physiotherapy and Paramedical Services
NCAHP issues curriculum handbooks
that prescribe the standards for
undergraduate physiotherapy education
undertaken through the Bachelor of
Physiotherapy (BPT) program, a 5-year
degree that includes a one-year mandatory
clinical internship (NCAHP Curriculum
for Physiotherapy, 2025, para. 3.4.2).
Eligibility for this program requires the
completion of 10+2 education with
proficiency in Physics, Chemistry, and
Biology. Through the communication
dated 09.01.2026, the NCAHP has notified
that admission is now through NEET,
with admission based on NEET merit/
marks and no separate cut-off percentile
requirement. For foreign national students,
the NCAHP material states that they
must obtain an equivalence certificate or
eligibility certificate from the respective
State Allied and Healthcare Council, and
their admission is subject to verification
of a valid visa and the applicable
institutional/university process. The
NCAHP Competency-based Curriculum
for Physiotherapy mandates a final exit
examination after completing clinical
fellowship training, which is conducted
once in a year.
The Master of Physiotherapy (MPT)
is a two-year postgraduate degree
allowing specialisation in fields
such as musculoskeletal, sports, pediatric,
and cardiopulmonary physiotherapy.
Admission to MPT programs
requires candidates to pass a Common
Entrance Test (CET) conducted either at
the state level or by individual universities
and institutions; however, some universities
also use NEET PG scores for MPT or allied
health seats.

India’s Services Sector: Insights on Regulatory Regime in Professional Services63
Paramedics
To be eligible for paramedical education
(Education of the Emergency Medical
Technologist), candidates must complete
their 10+2 education, generally with a
specialisation in science subjects (Physics,
Chemistry, and Biology). Process of
admission to diploma, undergraduate,
and postgraduate paramedical programs
varies depending on the course and the
institution, but generally involves a merit-
based selection through entrance tests, or
qualifying examinations as determined by
respective universities, state governments,
or national bodies. For example, courses
like the Bachelor of Science in Emergency
Medical Technology typically follow a
3–4-year curriculum, often including a
mandatory period of clinical internship or
practical training.
As per the NCAHP Emergency Medical
Technologist (Paramedic), Burn Care
Technologist and Advance care Paramedic
curriculum (NCAHP Curriculum for
Paramedics) guidelines it is recommended
that the students entering the Bachelors
of Emergency Medical Technologist
(Paramedic) programme at under
graduate level should have completed the
recognized secondary school studies as the
qualification stipulated is 10+2 with sciences
(Botany, Zoology, Physics and Chemistry)
or equivalent from a recognized university
or board-with 50% marks in Physics,
Chemistry, Biology which will provide the
foundation for and prepare them for higher
education studies (NCAHP Curriculum
for Paramedics, 2025, p. 41). The student
should have 17 years of age as on 31st
December of the admission year. Students
entering the programme at post graduate
level, should have completed the Bachelors
in Emergency Medical Technologist or
equivalent degree in a regular full time
on campus mode with a minimum of
50% marks from a recognized university.
Students entering the PhD program should
be as per the NCAHP regulations.
Candidates who have completed diploma
in emergency medical services (after
completion of 10+2 with science) or its
equivalent can also join the undergraduate
course. They would be eligible to join in 2nd
year of bachelors program if the numbers of
hours are in line with program of first year.
The total education therefore would be (2-
year diploma + 3 year of undergraduate
studies). The final year of the program
(lateral entry) would be internship.
It is recommended that any programme
developed from this curriculum should
have a minimum of the following duration
to qualify as a professional course: a 4-year
programme (including 1 year of clinical
training /internship) for the Bachelor’s
degree and a 2-year programme for the
Master’s degree. Further, there shall be
a third-party exit / licensure exam at the
end of the Internship (4th year) for the
Bachelor’s program and at the end of the
2nd Year for the Master's program. The
exit examination, or licensure examination,
serves as a requisite assessment for clinical
practice eligibility. While the university may
confer a degree completion certificate, it is
contingent upon the successful clearance
of the exit examination for clinical
practice privileges within India. Additional
criteria and regulations governing the
exit examination are in accordance with
the guidelines established by the NCAHP
(NCAHP Curriculum for Paramedics, 2025,
p. 42).
Additionally, the NCAHP has also issued
curriculums for other allied health
professionals and services, including
Physician Associates, Health Information
Management, Anesthesia and Operation

India’s Services Sector: Insights on Regulatory Regime in Professional Services 64
Theatre Technology, Medical Radiology
and Imaging Technology, Radiotherapy
Technology, Dialysis Therapy Technology
and Dialysis Therapy, Nutrition and
Dietetics, Optometry, Applied Psychology
and Behavioural Health, Medical Laboratory
Sciences, and Occupational Therapy.
While the AICTE prescribes model
curricula for some paramedical and allied
health courses, the main responsibility for
standardising and updating curricula in
these fields now lies with the Ministry of
Health and Family Welfare, through the
NCAHP. In parallel, the Healthcare Sector
Skill Council (HSSC) under the National
Skill Development Corporation (NSDC)
develops National Occupational Standards
(NOS) and Qualification Packs (QPs) that
define the competencies, performance
criteria, and required knowledge base
for various paramedical roles such as
Emergency Medical Technicians (EMTs),
Dialysis Technicians, and Operating Theatre
Technicians (Health sector Skill Council,
NSDC).
The NCAHP Act stipulates that
physiotherapists and paramedics must be
registered with the Central or State Register
maintained under the NCAHP in order to
legally practice in India (NCAHP Act, sec.14).
The candidate must make an application as
per Form B of the NCAHP Rules, 2021, along
with the registration fee of Rs. 2000 (NCAHP
Rules, 2021, Rules 11 and 12). Foreign-trained
professionals are also eligible for registration,
provided their qualifications are recognised
by NCAHP and comply with equivalency
norms (NCAHP Act, sec.39(1)(3)). Moreover,
as per Section 29 of the NCAHP Act, 2021,
professionals practicing without registration
or falsely claiming to be registered are subject
to penalties. Currently, there is no centralised
entry or exit exam for physiotherapists and
paramedics.
(iii) Other Restrictions for Professionals
Rendering Physiotherapy and Paramedical
Services
There is no specific residency requirement
to render physiotherapy and paramedical
services. The establishment of a
paramedical practice or physiotherapy
practice generally must be in adherence
to broader business laws applicable
alongside the specific regulations
introduced under the NCAHP Act,
2021. The legal forms of establishments
permissible for medical services under
the Clinical Establishments Act, 2010,
whether incorporated or unincorporated,
are also applicable to physiotherapy and
paramedical services. The NCAHP Act
aims to ensure that only qualified and
registered professionals render services,
irrespective of the corporate structure
employing them. (NCAHP Act, 2021,
Preamble).
Each state maintains its own guidelines
regarding professional conduct, and
in many cases, physiotherapists are
advised to refrain from direct or indirect
advertising. This generally includes patient
solicitation, self-promotion, or the use of
public education platforms for promotional
purposes. Instead, practitioners are
encouraged to share formal practice
updates and contribute to technical
publications in recognised professional
journals, in line with ethical standards set
by the respective state councils.
At present, no law prevents the paramedics,
including the allied and healthcare
professionals, from advertising their
services or soliciting patients. However, the
NCAHP Act provides the legal framework
for empowering its councils to establish
ethical conduct regulations.

India’s Services Sector: Insights on Regulatory Regime in Professional Services65
Box 15. India’s commitment for services provided by Midwives, Nurses,
Physiotherapists and Paramedical personnel
India does not commit to services provided by midwives, nurses, physiotherapists and paramedical
personnel under GATS.
In its FTAs with Korea, Japan, Singapore, Malaysia, Australia, the UAE, EFTA, and the UK, India’s
commitments in this sub-sector are identical to those made in the medical and dental services
sector (see Box 13).
However, in its FTA with Mauritius, market access through Mode 3 and national treatment through
Modes 1, 3, and 4 are subject to the condition that services by nurses and midwives professionals
qualified outside India can:
(i) engage in teaching and research subject to permissions from relevant authorities under
applicable domestic laws; and
(ii) practice nursing services in India are subject to registration with the relevant professional
body under a scheme of reciprocity.
In respect of physiotherapy and paramedical services, third-country qualified professionals can
provide services related to teaching, research or charitable purposes.
Figure 9 provides a graphical overview of the discussion presented in Chapter 2. It highlights the
key aspects of India’s regulatory regime for professional services across three core dimensions:
governing laws and regulations, required professional competencies, and restrictions on the
provision of professional services.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 66
Figure 9. Overview of India’s Regulatory Regime in Professional ServicesExit Exam Governing Laws
and Regulations Regulatory Body Legal Forms of
Establishment Licensing
Requirement Legal services Accounting, auditing, and
bookkeeping services Architectural services Engineering services Urban planning and landscape
architectural services Medical and dental services Veterinary services Services provided by
midwives, nurses Physiotherapists and para-
medical personnel Sectoral Classification CPC Prov. (W/120) Yes No Not in force Sole proprietorship Partnership Firm Limited Liability
Partnership Incorporated Company
Note: The figure depicts the three key dimensions using the traffic light method across the following select parameters: (1) laws and regulations that govern professional
practice, covering governing laws and regulations and regulatory body that governs the practice of the profession; (2) competencies of professionals, and whether an exit
examination is necessary to obtain a degree, and whether a license must be secured for practice; (3) restrictions on the rendering of professional services, particularly the
limitations placed on the legal forms of establishment through which professionals and entities are permitted to operate.

India’s Services Sector: Insights on Regulatory Regime in Professional Services673
Stakeholder
Consultation

India’s Services Sector: Insights on Regulatory Regime in Professional Services 68
Stakeholder consultations are a crucial
process of gathering insights on a subject,
enabling the inclusion of diverse perspectives
and practical experiences. This adds an
essential dimension to the secondary
research conducted in a study. Pursuant to
this report, consultations were held with
a diverse group of stakeholders, including
regulators, industry bodies, and individual
practitioners, who are directly or indirectly
involved in the professional services sector.
The stakeholders consulted comprised
of regulators responsible for framing and
implementing laws and regulations, industry
associations representing collective business
interests, individual entities and practitioners
engaged in rendering services, professional
bodies that oversee sector -specific
professional standards and ethics, and think
tanks offering independent policy analysis.
Each of these stakeholders offered a distinct
perspective; regulators provided insights
on policy and compliance, industry bodies
and individual practitioners highlighted
operational challenges, professional bodies
emphasised quality and professional
standards, while think tanks provided a
broader policy context.
This multi-stakeholder engagement was
instrumental in identifying areas where
existing regulations may be fragmented
or inconsistent, while also highlighting
opportunities to enhance the framework.
The inputs thereby gathered form the
substantive basis for the regulatory gaps and
challenges discussed in Chapter 4, and the
insights presented in Chapter 5 of this report.
By incorporating these diverse voices, the
study ensures that the challenges identified
and the insights presented in this report are
grounded in both policy considerations and
practical realities.
3.1 Stakeholder Consultation
at NITI Aayog with Regulators,
Industry Experts, and
Practitioners
The Services Division at NITI Aayog conducted
a stakeholder consultation on Professional
Services on April 30 and May 1, 2025, under
the chairmanship of Dr. Arvind Virmani,
Member, NITI Aayog. The consultation
brought together over 40 participants,
including regulators, representatives from
industry associations, policy think tanks,
academic experts, and practitioners across
various professional services sectors. The
wide-ranging participation ensured that the
discussion reflected both the regulatory and
operational dimensions of the professional
services ecosystem. A detailed list of
stakeholders who took part in the process is
provided in Annexure II.
The primary objective of the consultation
was to develop a deeper understanding of
the challenges faced by professional service
providers in the delivery of their services.
The discussions underscored the importance
of addressing such challenges not only
to improve domestic service delivery but
also to enhance India’s competitiveness in
international markets. Participants identified
regulatory and institutional challenges,
particularly in relation to educational
qualifications, licensing requirements,
recognition of professional competencies,
and sector-specific restrictions that constrain
market entry and practice.3
Stakeholder
Consultation
CHAPTER OUTLINE
3.1 Stakeholder Consultation
at NITI Aayog
3.2 Key Informant
Interviews
3.3 Consultation with
IFSCA at the GIFT City

India’s Services Sector: Insights on Regulatory Regime in Professional Services69
In addition to highlighting challenges, the
consultation provided a platform for stakeholders
to suggest possible policy interventions
and capacity-building measures that could
strengthen the enabling environment for
professional services in India. The discussion also
shed light on the need for proper implementation
of existing laws, harmonisation of standards
across jurisdictions within the country, and
adoption of emerging technologies and evolving
industry practices. Major themes that emerged
during the discussions for each sector were:
(i) Recognition: Recognition of
Qualifications, Licensing, Regulations.
(ii) Governance: Professional & Educational
Standards, Ethics and Accountability.
(iii) Continued Professional Development:
Maintenance of the standard of service,
Periodic Upskilling.
(iv) Liberalisation: Reciprocity, MRAs,
Barriers and other restrictions.
Based on the insights shared by the stakeholders during the consultation process, a series
of Key Informant Interviews was held, and a visit to GIFT City, Gandhinagar, Gujarat, was
undertaken to further understand the professional services ecosystem in India.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 70
3.2 Key Informant Interviews
(KIIs) with Regulators, Industry
and Professional Bodies
A series of Key Informant Interviews (KIIs)
were conducted between May and June 2025
with representatives from regulatory bodies,
industry associations, and professional
organisations. These focused discussions
were crucial for several reasons. First, such
key informants possess first-hand knowledge
of institutional structures, decision-making
processes, and enforcement practices,
insights that may not be evident from laws or
policy documents alone. Their perspectives
help reveal the “lived reality” of regulation,
including the interpretation, application and
practical implications of these regulations.
Second, direct engagement with regulators
and industry leaders allowed the study
to capture nuances around policy intent,
practical implementation issues, and
emerging challenges that may not yet
be documented. Third, KIIs served as a
valuable mechanism for validating findings
from secondary research and broader
consultations, ensuring that the analysis
rests on both empirical evidence and expert
judgment.
Moreover, these interviews facilitated candid
discussions about issues relating to legislative
framework, overlapping jurisdictions,
licensing requirements, and institutional
bottlenecks. By enabling a deeper dive
into specific sectors with key informants,
the KIIs generated granular insights that
complemented the broader themes emerging
from stakeholder consultations.
These included interviews with:
(i) The Institution of Engineers India (IEI)
for engineering services on May 14, 2025
(ii) The Institute of Chartered Accountants
of India (ICAI) for accounting, auditing,
bookkeeping, and taxation services on May
19, 2025
(iii) The Engineering Council of India (ECI)
for engineering services on May 22, 2025
(iv) The Services Export Promotion Council
(SEPC) on the broader professional services
landscape on June 3, 2025
(v) The Indian Association of
Physiotherapists on health services also on
June 13, 2025
(vi) The Indian National Association of Legal
Professionals (INALP) on legal services on
June 20, 2025.
3.3 Consultation with the
International Financial
Services Centres Authority
(IFSCA) at the GIFT City
The International Financial Services Centre
(IFSC) has been envisioned as India’s first
offshore hub for the supply of financial
services, operating within a Special Economic
Zone (SEZ), where most laws applicable in
the domestic tariff area (DTA) do not apply.
Here, the International Financial Services
Centres Authority (IFSCA), a unified regulator
for IFSCs, administers a distinct regulatory
regime aligned with global best practices to
facilitate cross-border service delivery. While
the IFSC is primarily focused on financial
services, its operations depend heavily on the
availability of high-skilled professionals such
as lawyers, accountants, consultants, and
other allied experts. To facilitate this need, the
IFSCA has introduced specific frameworks,
such as the Bookkeeping, Accounting,
Taxation, and Financial Crime (BATF) and
Ancillary Services regulations, to regulate the

India’s Services Sector: Insights on Regulatory Regime in Professional Services71
provision of professional services within GIFT
City, ensuring their seamless integration into
the broader financial services ecosystem.
In order to closely study this unique
ecosystem, the Services Division undertook
a visit to the GIFT City from May 27 to May
29, 2025. The purpose of the visit was to
understand how professional services are
regulated, supplied, and facilitated by the
IFSCA within the GIFT City, and to explore
the extent to which these practices could
inform broader policy approaches in the
DTA. The visit also aimed to assess the
functioning of the IFSC from an ease-of-
doing-business perspective, specifically
examining how licensing, compliance, and
operational approvals, facilitated through
a single window clearance system, differ
from processes in the DTA. By engaging
with departments of the IFSCA, including
the Development, Legal, and Technology
divisions, as well as with BATF professionals
and ancillary service providers, the Services
Division sought to understand the specific
institutional mechanisms that enable GIFT
City to function as a competitive international
hub.
In this context, discussions with BATF and
ancillary service providers were organised
around five key themes:
(i) Regulation of professional services by
the IFSCA.
(ii) Conditions of supply of professional
services.
(iii) Nature of services rendered by
professionals.
(iv) Role of the regulator.
(v) Ease of doing business at IFSCs.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 72

India’s Services Sector: Insights on Regulatory Regime in Professional Services734
Regulatory Gaps
and Challenges

India’s Services Sector: Insights on Regulatory Regime in Professional Services 74
The regulatory gaps listed in this chapter
are a collation of the sector-specific
challenges identified during the stakeholder
consultations held with regulators, industry
associations, professional bodies, individual
practitioners, think tanks, and NITI Aayog’s
internal research.
4.1 Legal Services
4.1.1 Recognition
The legal landscape has undergone a
significant transformation in recent years.
The scope of legal practice and specialisation
has expanded considerably, with increasing
financial stakes, evolving business structures,
and an expanded role of law, not only as a
service to people but also as a strategic
enabler for complex and modern enterprises.
This ecosystem is supported by a broader
spectrum of professionals, such as in-house
legal counsels, legal process outsourcing
(LPO) professionals, Advocates and other
legal consultants. However, the Advocates
Act, 1961, in its present form, recognises
and regulates a single category of legal
practitioners, i.e. Advocates (Advocates Act,
section 29) and thereby advocacy. This leaves
a regulatory vacuum with respect to other
legal practitioners as well as other forms
of legal service. Thus, adoption of a more
modern, diversified and inclusive approach
on recognition of legal professionals may
be timely and in line with the contemporary
Indian legal landscape.
4.1.2 Endeavour Regulatory Clarity
Recently, the BCI took steps to liberalise
the legal services sector through the
implementation of the Rules for Registration
and Regulation of Foreign Lawyers and
Foreign Law Firms in India, 2022 (amended
and notified in 2025). Under these rules,
foreign lawyers are authorised to practice,
on a reciprocal basis, limited advisory and
non-litigious work relating to foreign law,
international law, and arbitration in India,
while the practice of Indian law remains
prohibited. However, clarification on certain
pertinent issues, such as the taxation of
revenue earned by foreign law firms, the
possibility of foreign financing in legal
services/foreign direct investment inflows,
the scope of permissible collaboration
between Indian and foreign law firms, etc.,
may be helpful to ensure consistency and
transparency.
4.1.3 Limitations on Permissible
Forms of Establishment
Under the current legal framework,
advocates are permitted to practice as sole
proprietorships, partnerships or limited
liability partnerships (LLPs). However, the
incorporation of law firms as private limited
companies and the formation of multi-
disciplinary practices remain prohibited.
4.1.4 Advertising Norms
Presently, Rule 36 of the BCI Rules prohibit
advocates from advertising or soliciting work,
directly or indirectly, across any medium, and
places restrictions on the size of nameplates/
signboards and content. In 2008, the BCI
amended this rule vide Resolution No.
50/2008, to permit advocates to maintain
websites containing basic details such
as name, contact information, enrolment
number, qualifications, and areas of practice,
accompanied by a disclaimer attesting
the truth of the information. While these 4
Regulatory Gaps and
Challenges
CHAPTER OUTLINE
4.1 Legal Services
4.2 Accounting, Auditing,
and Bookkeeping
Services
4.3 Architectural Services
4.4 Engineering Services
4.5 Healthcare and Allied
Healthcare Services

India’s Services Sector: Insights on Regulatory Regime in Professional Services75
restrictions aim to uphold the profession’s
dignity and ethical standards, they may
also limit the visibility and accessibility of
legal services in an increasingly digital and
competitive environment.
4.1.5 Professional Mobility
Cross-border mobility of professionals in the
legal services sector is typically governed by
fulfillment of country-specific qualifications
and licensing standards. At present, the BCI
has not entered into any mutual recognition
agreements (MRAs) with foreign regulatory
bodies that would further support the
recognition of legal qualifications or formalise
mechanisms to support cross-border
mobility of professionals. While the BCI has
signed a Memorandum of Understanding
with the Bar Council of England and Wales to
promote cooperation based on reciprocity,
this understanding does not extend to
facilitating the mobility of legal practitioners
across borders.
4.1.6 Continued Professional
Development (CPD) and Skilling for
all Practitioners
While the BCI and State Bar Councils have
acknowledged the importance of continued
legal education and upskilling, there is
currently no formal or mandatory framework
for CPD to ensure consistent and uniform
standards of legal practice across the
profession. Additionally, there is a notable
gap in structured skilling frameworks for
allied legal professionals, such as paralegals,
law clerks, and legal assistants, who play a
crucial role in supporting legal services.
4.2 Accounting, Auditing and
Bookkeeping Services
4.2.1 Restrictions on foreign
participation and practice rights:
(i) India’s regulatory regime maintains
a tight posture towards the independent
practice of foreign accountants and audit
firms in India. To operate in India, foreign
professionals are required to either obtain
a registration from ICAI in accordance with
Indian law or form affiliations with Indian
chartered accountancy firms.
(ii) Recognising the significance of such
global affiliations, the ICAI, through the
Committee for Aggregation of CA Firms,
released the Exposure Draft on Proposed
Guidelines for Overseas Network for
public consultation in June 2025. After
the due consultation process, these
guidelines were notified as the ICAI (Global
Networking) Guidelines, 2025 on February
11, 2026. It establishes a comprehensive
regulatory framework governing the
formation, registration and operation of
global networking arrangements between
Indian and overseas entities. However, the
independent practice of foreign accountants
remains restricted, partially preserving the
constraint on foreign participation. Notably,
the guidelines have been kept in abeyance
until further orders by ICAI through an
announcement dated 15 July, 2026.
4.2.2 Clarity on Regulatory Roles of
ICAI and NFRA in India’s Accounting
and Auditing Landscape
The regulatory framework governing
accounting and auditing in India is
characterised by the dual presence of the
ICAI and NFRA. Although the roles of ICAI
and NFRA are meant to complement each
other, their respective mandates regarding
the authority to prescribe and notify
accounting and auditing standards have, at
times, intersected, leading to uncertainty
and overlap in their jurisdictions.
In 2024, the ICAI introduced new Standards
on Quality Management (SQMs) aimed
at revising existing auditing norms. This
elicited questions on the powers of ICAI and
NFRA. In response, the NFRA sought a legal

India’s Services Sector: Insights on Regulatory Regime in Professional Services 76
opinion from the Solicitor General of India,
wherein it was clarified that ICAI’s powers
under section 143(10) of the Companies Act,
2013, are advisory and transitional in nature.
This states that the regulatory oversight
of auditing standards remains under the
purview of NFRA. Further, NFRA draws its
powers from section 132 of the Companies
Act, 2013, wherein it is granted the right to
recommend accounting standards to the
central government (T. Mehta. Legal Opinion,
2024). 
Thus, this recent clarification delineates the
regulatory jurisdiction of both ICAI and NFRA.
NFRA is affirmed as the independent regulator
for accounting and auditing standards
applicable to public interest entities, while
the ICAI continues to play a critical role in
regulating the profession through education,
licensing, training, and development, and by
overseeing auditors of private companies.
The ICAI may recommend accounting and
auditing standards in consultation with
NFRA, which is, in turn, recommended to
the central government, thus preserving a
consultative and collaborative framework.
4.2.3 Pursue Mutual Recognition
Agreements or Reciprocity
Agreements
ICAI has entered into a limited number of
MRAs or reciprocity arrangements with
selected foreign professional accounting
bodies. Expanding and deepening this
MRA network would further enhance the
international mobility of Indian accounting
professionals and strengthen the global
recognition of Indian qualifications. 
4.2.4 Endeavour Regulatory Clarity
and Skilling for bookkeepers
Bookkeeping professionals play a key role
in ensuring accurate financial reporting and
tax compliance. However, current oversight
mechanisms remain limited in scope, with no
uniform standards for qualifications, ethical
conduct, or record-keeping. Establishing a
clear regulatory framework with well-defined
entry criteria, professional obligations, and
supervisory mechanisms could enhance
bookkeeping services. Moreover, the absence
of formal training or skilling requirements
may constrain aspiring bookkeepers
from fully leveraging opportunities in the
profession. Outsourcing bookkeeping to
India, particularly, offers global businesses
significant advantages, including cost saving,
enhanced accuracy, and real-time financial
insights. Thus, clear guidelines for the
independent practice of bookkeepers may
further enhance the service.
4.2.5 Enhance Existing Digital Tools
for Audit and Accounting Oversight
To ensure effective oversight and build
stakeholder trust, it is crucial to have easy
and reliable access to information on audit
and accounting professionals. Thus, current
digital platforms may be upgraded by
integrated databases, adding user-friendly
search features, and adopting standardised
data formats. Additionally, establishing
clear guidelines on data maintenance,
regular updates, and platform governance
would improve transparency, facilitate due
diligence, and align the domestic digital tools
with global best practices.
4.3 Architectural Services
4.3.1 Legal Structures for
establishment
The current regulatory framework permits
architects to establish commercial presence
mainly through sole proprietorships or
partnership firms. Other legal forms of
establishment, such as limited liability
partnerships (LLPs) or incorporated
companies, are not permitted under the
existing regulatory framework. This restriction
limits the options available to professionals
in structuring their business operations
and stands in contrast to jurisdictions such

India’s Services Sector: Insights on Regulatory Regime in Professional Services77
as the United Kingdom, New Zealand, and
Singapore, where a more diverse range of
legal structures are permitted.
4.3.2 Equivalence of Foreign
Qualifications
While the Schedule to TAA, 1972 lists
foreign qualifications recognised under
section 15(1) of the Act, the Act, rules, and
regulations thereunder, currently does not
have a structured mechanism for evaluating
or granting equivalence to architectural
qualifications awarded by foreign
institutions. As a result, professionals trained
abroad often encounter challenges in having
their academic credentials recognised
for registration and practice in India. This
absence of an equivalence framework
creates challenges for foreign-trained Indian
graduates returning to the country, as well
as for foreign professionals who may wish to
practice in India.
4.3.3 Professional Examination for
Licensing
Architects in India are not required to appear
for a professional licensing examination after
completing their academic qualifications.
Registration as an architect under TAA,
1972, is currently based on completion of
a recognised degree program, without
an additional assessment of professional
readiness. A professional examination
could add an additional layer of assurance
regarding the credibility and competence
of architects, particularly since their work
has a direct bearing on public safety and the
quality of infrastructure.
4.4 Engineering Services
4.4.1 Legal Framework for Engineers
India currently does not have a
comprehensive legal framework that governs
the practice of engineers, including civil
engineers engaged in construction and
related activities. Though civil engineers play
a vital role in infrastructure development
and projects of public importance, their
professional practice is shaped primarily by
institutional/professional frameworks and
industry norms but not statutory regulations.
Eligibility to practice is largely determined
by academic qualifications granted by
recognised educational institutions,
while professional conduct is guided by
professional bodies, their codes of conduct,
and standards promulgated by Bureau of
Indian Standards (BIS) for construction
related activities. In the absence of a
dedicated statutory framework, the practice
of engineering retains a degree of flexibility;
however, a structured framework can provide
consistency, accountability, and clarity in
defining professional responsibilities, as
seen in allied professions. The development
of a statutory/legal framework for certain
specialized categories of engineers could
help strengthen the regulatory regime in this
sector.
4.4.2 Overlaps with Architectural
Services
In the current regulatory landscape, there
are some functional overlaps between the
services offered by architects and engineers
engaged in construction-related activities.
This overlap stems partly from section 37
of TAA, 1972, which is limited to protecting
the title and style of “Architect.” The Act
does not explicitly restrict the rendering
of architectural services by individuals
who are not registered architects. Judicial
interpretations have supported this view,
recognising that engineers engaged in
construction-related activities may also
undertake certain services that fall within
the ambit of architectural services. In the
absence of a dedicated legal framework for
civil engineers, the division of responsibilities

India’s Services Sector: Insights on Regulatory Regime in Professional Services 78
between architects and civil engineers has
at times remained open to interpretation,
leading to overlaps that rely more on practice
and convention than on clear statutory
demarcation.
4.5 Healthcare and Allied
Healthcare Services
4.5.1 Multi-layered Regulatory
Governance and Jurisdictional
Overlaps
The oversight framework for certain
healthcare segments involves diverse
regulatory authorities. For example,
regulatory authorities for AYUSH practitioners
include the Ministry of AYUSH, various state
AYUSH bodies, and the National Commission
for Indian System of Medicine (NCISM). This
multi-tiered governance structure results in
jurisdictional ambiguities and enforcement
inconsistencies, potentially impacting
seamless regulatory governance.
4.5.2 Barriers to Interstate
Professional Mobility
The registration of medical and allied
healthcare professionals is primarily overseen
by individual State Medical, Nursing, and
Allied Health Councils, with national bodies
such as the NMC, NNMC and NCAHP
providing regulatory oversight and standard
setting functions. However, a unified national
system for license portability across states
is yet to be established. For example, the
Maharashtra Medical Council mandates
that doctors registered in other states must
submit a fresh application, along with a
No Objection Certificate (NOC) from their
original state council, before being permitted
to practice in Maharashtra (Maharashtra
Medical Council). Such administrative
requirements present barriers to interstate
professional mobility, constraining the free
movement of medical practitioners, nurses,
and allied health workers. This, in turn,
limits workforce flexibility and may hinder
equitable access to healthcare services
across different regions, particularly in areas
facing provider shortages. In this context, the
NMC’s draft amendment of 7 April 2026 to
the Registration of Medical Practitioners and
License to Practice Medicine Regulations,
2023, for Armed Forces Medical Services
practitioners is a notable exception, as it
permits them to remain registered with one
State Medical Council while being authorised
to practice across India by virtue of service
obligations.
4.5.3 Partial Operationalisation of
the National Commission for Allied
and Healthcare Professions Act
While the NCAHP Act, 2021, has seen partial
operationalisation through the constitution of
the NCAHP and the rollout of the standardised
curricula, its full operationalisation remains
incomplete, particularly at the state level. As
of 2025, only 26 states and union territories
have constituted the required State Allied
and Healthcare Councils, of which a few
councils have deviations from the NCAHP
Act and further a few others states have
not notified the constitution of such state
councils (Ministry of Health and Family
Welfare Letter, Z.20025/7/2025-NCAHP).
This creates regulatory ambiguity and
insufficient oversight for numerous allied
health professionals, including those in
paramedical fields. This delay impedes the
standardisation of education, licensing, and
practice benchmarks, impacting the scope of
practice and accountability in this sector.
4.5.4 Unrealized Mandate of the
National Exit Test (NExT)
Despite being mandated under the NMC Act
(section 15), the NDC Act (section 15), and the
NCISM Act (section 15), NExT examination
is yet to be introduced. This deferral may

India’s Services Sector: Insights on Regulatory Regime in Professional Services79
slow the progression of medical education
and licensing processes, potentially
affecting efforts to standardize competency
assessment and streamline registration for
medical graduates across India.
4.5.5 Pursue MRAs and Reciprocity
Agreements
India currently has limited number of
MRAs or reciprocity arrangements
covering medical, dental, veterinary,
nursing, midwifery, paramedical, and
physiotherapy professionals. Expansion of
such frameworks with more professional
bodies will enhance international mobility
and collaboration of professionals, impacting
the global responsiveness and efficiency
of healthcare service delivery. Establishing
such frameworks could support workforce
mobility and align domestic standards with
international best practices.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 80

India’s Services Sector: Insights on Regulatory Regime in Professional Services815
Insights and
Way Forward

India’s Services Sector: Insights on Regulatory Regime in Professional Services 82
This chapter builds on the regulatory gaps
detailed in Chapter 4 and presents a set
of insights that emerged from stakeholder
consultations with regulatory bodies,
industry representatives, and professional
associations. The discussions during these
consultations provided valuable perspectives
on the challenges and opportunities within
the professional services sector. Drawing
on these perspectives, the chapter outlines
a four-pronged strategy to strengthen
the professional services ecosystem and
sector-specific insights for a way forward
to achieving the Vision 2047 of a Viksit
Bharat. Additionally, in order to help initiate
transformation, as guided by the stakeholder
consultation, reference may be made to
global practices. In this regard, an attempt
has been made to compile the best practices
in select jurisdictions, which are attached as
Annexure I.
It is important to note that some of these
insights may carry legal, regulatory, or
institutional implications. Therefore, any
consideration or implementation of these
ideas would benefit from a broad-based
and inclusive consultation with all relevant
stakeholders. The insights presented in this
chapter are not intended to be prescriptive,
rather as reference points to stimulate further
dialogue, encourage deeper analysis, and
support evidence-based policymaking. The
overarching objective is to foster an enabling
environment where professional services can
contribute effectively to economic growth
and social welfare, while upholding regulatory
integrity and protecting the public interest.
5.1 Four-pronged Strategy
to Strengthen the Professional
Services Sector
The professional services sector in India may
benefit from a four-pronged strategy aimed
at strengthening its overall growth and
competitiveness. This strategy focuses on
(i) continuous professional development, (ii)
transparent and good regulatory practices,
(iii) the elevation of professional services
within the services value chain, and (iv) the
advancement of emerging trends in the sector.
These strategic priorities are applicable
across all sub-sectors of professional
services, ensuring a consistent approach
to raising service standards and expanding
opportunities for the professionals. Together,
they aim to strengthen the workforce, improve
the regulatory regime, and secure a more
prominent position for Indian professionals
in global markets. Continuous
Professiona l
Development fo r
Professionals Adoption of best
practices in
professional services Elevate professional
services within th e
services value chain Advance the
emerging trends in
professional services 5
Insights and
Way Forward
CHAPTER OUTLINE
5.1 Four-pronged
Strategy to Strengthen
the Professional
Services Sector
5.2 Sector-specific
Insights

India’s Services Sector: Insights on Regulatory Regime in Professional Services83
5.1.1 Continuous Professional
Development for Professionals
Developing a CPD and upskilling framework
is essential to nurture lifelong learning and
align professional services with emerging
global standards. Around the world, CPD
is a common practice used to ensure that
professionals remain competent and up
to date in their fields. It underscores the
dynamic nature of professional competence,
which evolves over time through exposure to
new knowledge, practices, and technologies.
For professionals, it provides opportunities
to refresh and expand their skills beyond
formal education, boosting their confidence
and adaptability. For clients and the public,
CPD frameworks signal a commitment to high
standards, accountability, and quality service.
In India, there is no legal framework mandating
CPD requirements with an enforceable
CPD-hour regime for professionals. While
some professions have mandatory CPD
enforcement, with structured pathways
others do not, contributing to uneven
competence standards. Professions such
as legal services, architectural services,
engineering services, and allied health
services (at draft stage) do not appear to have
a mandatory/enforceable CPD. By contrast,
accountants/auditors, medical practitioners,
and nurses, have structured and mandatory
frameworks, resulting in a fragmented
professional services landscape. A well-
structured CPD framework for professionals
would reinforce sectoral competence,
elevate service quality, and build public
trust by standardising responsiveness to
economic and technological shifts across all
professions.
5.1.2 Adoption of best practices in
professional services
Regulatory reforms to enhance transparency
Implementing regulatory reforms to enhance
transparency in administrative processes may
help maximise exports and strengthen India’s
services trade regime. Establishing dedicated
administrative units for specific sectors may
help professional services associations and
regulators engage constructively with their
foreign counterparts to facilitate mobility of
professionals and enhance their opportunities
in foreign markets. A similar approach has
been followed by the Department of Foreign
Affairs and Trade (DFAT) of Australia which
established a Professional Services and
Mutual Recognition Unit responsible for
internationalization of the professional
services sector (Department of Foreign
Affairs and Trade, n.d.). It assists the Australian
professional associations and regulators
to make arrangements for professionals
to practice internationally, based on the
qualifications in their home country and
licensing through MRAs. Such an approach
could particularly be instrumental in nursing
services, traditional medicine and other
allied health services where qualification
assessment often depends upon the criteria
applicable in the home country.
Transparency and Good regulatory practices
to enable regulatory cooperation
Transparency and good regulatory practices
have emerged as the key parameter of
an open, facilitative and business friendly
environment. Transparency of applicable
laws and regulation provides predictability,
certainty and stability to service suppliers.
Clear and publicly accessible authorisation
criteria attract service suppliers and improves
general competitiveness. Accordingly,
guidelines may be envisaged for streamlining
regulatory practices in professional services,
aimed at improving the ease of doing
business reforms in the services sector.
These measures could be progressively
benchmarked against international best
practices and include fundamental steps
such as clearly defining and publicly sharing
qualification and licensing requirements,

India’s Services Sector: Insights on Regulatory Regime in Professional Services 84
providing readily accessible contact details of
relevant authorities, establishing mechanisms
for appeal or review, publishing and promptly
communicating decisions, and indicating
timeframes for application processing.
By enhancing access to information
and streamlining procedures, India can
create a more predictable and efficient
regulatory environment that facilitates the
global mobility of its professionals. For
example, Malaysia Productivity Corporation
established the Unified Public Consultation
(UPC) online portal - Malaysia’s 2019 model,
to centralises and standardises stakeholder
engagement. Such a single-window platform
makes regulatory consultations more
accessible, ensure a clear and consistent
information flow, and facilitate the meaningful
participation of relevant stakeholders
(Ministry of International Trade and Industry,
2019; Unified Public Consultation, n.d.).
Adopting good regulatory practices (GRPs)
involves a conscious and progressive shift
towards business-friendly practices along
with streamlining regulatory processes.
By establishing clear, transparent and
consistent guidelines, regulators can ensure
alignment in their regulatory approach,
thus reducing conflict and enhancing
mutual understanding. GRP measures may
include adopting standardised processes,
establishing common goals and facilitating
regular dialogue with all interested
stakeholders to address their challenges and
enhance their market opportunities.
Implementing GRPs is crucial to fostering
effective cooperation among regulators
across different sectors and nations. This
does not imply benchmarking domestic laws,
practices or policies with those of foreign
jurisdictions, but adopting practices and
developing policy frameworks conducive to
a more business-friendly and transparent
regime. GRPs could ensure proportionate,
predictable regulations that adapt to
technological disruptions like AI and fintech,
ultimately enhancing service quality, public
trust, and India’s position in high-value global
services value chains
5.1.3 Elevate professional services
within the services value chain
India can elevate its position in the Global
Value Chain (GVC) for professional services
by transitioning from cost-based delivery to
high-value, knowledge-intensive activities
such as R&D, strategic technology operations,
engineering design, consulting etc. India’s
GCCs, currently around 1700 in number and
employing over 1.9 million professionals,
are already driving this shift by serving as
strategic innovation hubs and localising
advanced functions such as AI and machine
learning, IP strategy and complex financial
modeling (Press Information Bureau, 2025;
Zinnov-Nasscom, 2025). Further, India’s cost
arbitrage combined with its vast skilled talent
pool, already provides a strong foundation
for deeper integration into the GVC, which
can be further unlocked through targeted
policy action.
Modernising regulatory frameworks to
enable strategic advisory services, foster
innovation, and reduce trade barriers will
be key to accelerating this transition and
enabling Indian firms to capture higher-
value work. Such a shift would enable
Indian professional services to participate
more meaningfully across many segments
including legal services (evolving from
process-driven outsourcing to analytical
projects); engineering (advancing to design
and development); management consulting
(shifting from data processing to scenario
modeling) etc. Together, these changes may
help in capturing greater economic value
while strengthening India’s integration into
global markets.

India’s Services Sector: Insights on Regulatory Regime in Professional Services85
5.1.4 Harnessing Emerging Trends
to Transform Professional Services
Professional services, by their nature, rely
heavily on human insight, intuition, and client
interactions. However, emerging disruptions
including green transition, geopolitical
tensions and, particularly, technological
advancements such as AI, are transforming
the professional services sector by creating
new revenue streams and service lines.
Enabling firms to adapt to the structural
shifts driven by these emerging trends will be
critical to capturing high-value opportunities
in the global market.
Technological advancements are enhancing
both efficiency and value creation in service
delivery. While digital tools can streamline
application, approval, renewal, and other
administrative processes, the larger
opportunity lies in the adoption of cognitive
technologies such as AI, machine learning
and automation. These advancements
are reshaping the sector by automating
routine tasks such as data processing, while
increasing demand for advanced analytics
and strategic advisory. These technologies
reduce human error, enhance productivity
and leverage predictive analytics to improve
decision-making. Tools such as AI-powered
chatbots, intelligent document processing,
and blockchain-based smart contracts
are already transforming sectors like law,
accounting, and consulting. For India, this
presents an opportunity to move beyond
back-end execution toward AI-enabled
decision-making, including the development
of proprietary tools for financial modeling,
legal analytics, and consulting, positioning
itself as a hub for innovation-led professional
services.
As highlighted in the World Economic Forum’s
Future of Jobs Report 2025, technological
change is expected to both displace and
create large numbers of jobs by 2030, which
makes accessible reskilling and upskilling
especially important for professional services
providers that want to remain competitive in
AI-enabled work environments.
At the same time, the global push toward
sustainability and net-zero commitments
is creating a rapidly expanding market for
environmental, social, and governance (ESG)
services. It has created new requirement
such as mandatory ESG disclosures, carbon
accounting, climate-risk assessment,
sustainable finance, and advisory services for
renewable energy, including solar, wind, and
green infrastructure projects. This has pushed
firms to provide new offerings such as ESG
audits by accounting firms, ESG advisory by
consulting firms, ESG diligence and climate
advisory by law firms and development
of ESG software platforms for carbon
tracking etc. by technology companies.
India can leverage these opportunities to
emerge as a key provider of green and ESG
advisory services, particularly in areas such
as renewable energy transitions, carbon
markets, and green finance.
Geopolitical uncertainty and trade
fragmentation, have further created
new avenues for complex, high-value
advisory services, particularly in supply
chain restructuring, risk management and
regulatory compliance. As the demand for
trusted regulatory compliance and advisory
grow, India is increasingly seen as a stable and
reliable hub for global firms. This is reflected in
the continued expansion of GCCs, which are
increasingly anchoring sophisticated work in
analytics, compliance, transformation, and
domain-specific advisory. Together, these
developments reinforce the need for Indian
professional services to evolve beyond
cost-led support functions towards AI-
enabled, sustainability-oriented, and globally
integrated knowledge services.
5.2 Sector-specific insights
The previous section outlined a four-pronged
strategy for the holistic development of

India’s Services Sector: Insights on Regulatory Regime in Professional Services 86
the professional services sector. Building
on this strategy, this section highlights the
sector-specific factors that may impact its
advancement.
5.2.1 Legal Services
Regula tory
Harmoniza tion
and Clarity
Professional
Mobility
Recognition
of all L egal
Professionals
Revisit
Advertising
Norms
Legal f orms
of Practice
Skilling of
Allied L egal
Professional s
Modernise
(i) Recognition of all Legal Professionals
Expansion of statutory recognition to
legal professionals other than advocates
may facilitate a more inclusive and
representative framework aligned with
India’s contemporary legal and commercial
landscape. This shift would recognise a
diverse ecosystem of legal professionals,
including in-house counsels, legal process
outsourcing (LPO) professionals, and other
legal consultants, offering a more inclusive
perspective on the vital role of these
professionals and India’s evolving legal
services landscape.
Recognising a broader spectrum of legal
professionals may also support the evolution
of ethical standards tailored to their roles,
enhance transparency, and contribute to
increased public trust in legal service delivery.
Notably, the General Counsels’ Association
of India (GCAI) and Society of Indian Law
Firms (SILF) have formally advocated
for the statutory recognition of general
counsels of companies, underscoring the
growing consensus on potential reforms
(Bar and Bench, 2024).
(ii) Regulatory Harmonisation and Clarity 
With the ongoing liberalisation of the legal
sector and in alignment with the vision
of Viksit Bharat, there is potential for
increased investment in the legal domain.
In this context, enhanced clarity on certain
matters may be considered, such as the
taxation framework for revenue generated
by foreign law firms in India, conditions/
limitations on permitted partnerships
between Indian and foreign law firms,
permissibility of foreign investments in legal
services in the context of foreign law firms
and Indian law firms registered as foreign
law firms under the BCI Rules of 2025.
Clarifications regarding such matters may
lead to enhanced transparency, regulatory
clarity and streamlining of reforms.
(iii) Professional Mobility
Exploring potential MRAs with foreign
counterpart bodies may pave the way for
easier recognition of legal qualifications
and the development of a structured
framework for bridge courses, licensing
procedures, and other qualifying
conditions, grounded in the principle

India’s Services Sector: Insights on Regulatory Regime in Professional Services87
of reciprocity. Such initiatives may
significantly enhance the cross-border
mobility of qualified legal professionals
and, by promoting reciprocal
arrangements, could also support greater
participation of Indian legal practitioners
in the global legal services market.
(iv) Revisit Advertising Norms
Under rule 36 of the BCI Rules, legal
professionals are subject to restrictions on
advertising their services. These provisions
prohibit the solicitation of work and the
advertisement of legal services, whether
directly or indirectly, across any medium.
In light of the evolving nature of the
legal profession, particularly in a digitally
driven, client-oriented marketplace, a
contemporary approach to advertising
may be explored. This approach to
advertising may enable legal professionals
to responsibly leverage digital tools to
increase visibility, expand outreach, and
better serve clients, while maintaining
the dignity and ethical standards of the
profession.
(v) Modernise Legal Forms of Practice
To support evolving business needs,
permitting law firms to operate as multi-
disciplinary practices (MDPs), subject
to safeguards such as i) restrictions
on non-lawyer ownership and voting
rights; ii) confidentiality and conflict-
of-interest protocols; iii) mandatory
registration and regulatory oversight,
etc., may be considered. This may enable
legal service providers to adopt modern
business structures and enhance global
competitiveness.
(vi) Skilling for Allied Legal Professionals
Allied legal professionals, including
paralegals, law clerks, and legal assistants,
play a crucial role in supporting the delivery
of legal services. Establishing a dedicated
framework for their training and skilling can
help identify talent, enhance professional
capabilities, and expand opportunities
within the sector. While not all legal
aspirants may pursue careers as advocates,
such skilling initiatives may ensure valuable
pathways for their participation and growth
in the broader legal ecosystem.
5.2.2 Accounting, Auditing and Bookkeeping Services
Pursue Mutual Recognition Agreements
(MRAs)
Enhancing the regulatory oversight and
skilling of bookkeeping professionals
01
02
Phased Accreditation P athways for
Foreign P rofessionals
03

India’s Services Sector: Insights on Regulatory Regime in Professional Services 88
(i) Pursue Mutual Recognition
Agreements (MRAs)
Expansion of MRAs with additional
international/foreign accounting bodies
would support the recognition of Indian
qualifications abroad and vice versa,
thereby enabling greater mobility for Indian
accounting professionals while allowing
reciprocal access for foreign professionals.
(ii) Enhancing the Regulatory Oversight
and Skilling of Bookkeeping Professionals
Bookkeeping plays a foundational
role in financial reporting and tax
compliance, yet the profession currently
operates with limited formal oversight.
Expanding regulatory oversight through
a comprehensive legislative or regulatory
framework by defining qualifications,
ethical standards, and record-keeping
practices would enhance the quality
and credibility of bookkeeping services.
Formal recognition and regulation would
also support their integration into the
mainstream economy and promote greater
financial transparency, compliance and
integrity of financial information over time.
In India, presently, the IFSCA in GIFT City
governs bookkeeping services under the
IFSCA (Bookkeeping, Accounting, Taxation
and Financial Crime Compliance Services)
Regulations, 2024.
Further, a formal training and skilling
framework could equip aspiring
bookkeepers with the necessary knowledge
and competencies, thereby enhancing their
ability to access and leverage employment
opportunities in the profession.
(iii) Phased Accreditation Pathways for
Foreign Professionals
Establishing a structured accreditation
system for qualified foreign professionals
seeking to operate in the Indian market may
facilitate smoother and more transparent
foreign participation. This system could
function as an optional, complementary
pathway, preserving regulatory integrity
while enhancing access, rather than
replace the existing licensing requirements.
Eligibility for such accreditation may be
limited to individuals with recognised
foreign qualifications, a minimum period of
professional experience, and demonstrable
expertise in areas where the Indian market
would benefit from specialised skills.
5.2.3 Architectural and Allied Services
Permit a W ider
Range of L egal
Structur es
Streamlined
registration
mechanism
Regula tory
framework for
landscape
architects
Pursue Mutual
Recognition
Agreements
(MRAs )
Professional
Examina tion
for Lic ensing
of Ar chitects

India’s Services Sector: Insights on Regulatory Regime in Professional Services89
(i) Professional Examination for Licensing
of Architects
A professional licensing exam intended
to assess practical knowledge, legal and
regulatory awareness, ethical standards, and
the ability to apply architectural principles in
real-world scenarios could help ensure that
only qualified professionals are entrusted
with designing the built environment. Such
an exam could standardize the assessment
of competency across graduates from
different institutions. The current regulatory
framework in India does not mandate a
professional licensing examination before
obtaining a registration from the CoA.
Registration is granted solely on the basis
of completing a recognised academic
programme, without a formal assessment of
professional competence. Thus, a framework
for a professional licensing examination may
enhance public confidence and ensure that
newly registered architects are equipped to
meet the complex demands of professional
practice.
(ii) Streamlined Registration Mechanism
The current system of registration for
architects in India reflects a great degree
of diversity. While the CoA primarily grants
registrations, certain local authorities
may also require separate or independent
registrations, even though TAA, 1972,
does not provide for such a requirement.
For example, Rule 23 of the Tamil Nadu
Combined Development and Building
Rules, 2019, require architects to obtain
further registration with local authorities
for a prescribed fee. Similarly, Rule 99 and
Appendix H1-A of the Kerala Municipality
Building Rules, 2019, mandate additional
registration of an architect with the
registering authority for a prescribed
fee. Thus, streamlining the registration
procedure may help enhance clarity and
create a cohesive system of registration.
(iii) Permit a Wider Range of Legal
Structures
Easing current restrictions on legal forms
of establishment to permit architects to
operate not only as sole proprietors or
partnerships but also as LLPs may provide
greater flexibility. This would encourage
growth, strengthen liability management,
and attract investment in professional
practice.
(iv) Regulatory Framework for Landscape
Architects
Section 37(1)(a) of the TAA, 1972, permits
landscape architects to use the title and style
of “Architect”; however, it does not regulate
the practice of landscape architecture.
While CoA oversees the educational aspects
of landscape architecture, there is currently
no regulatory framework governing its
professional practice. In this context, a legal
framework to regulate landscape architects
may help establish clear guidelines for
licensure or registration, set standards for
ethical conduct, and create a mechanism
for professional oversight. This would
not only strengthen the credibility of the
profession but also support national goals
related to sustainable urban development
and climate resilience.
(v) Pursue Mutual Recognition
Agreements (MRAs)
At present, there are no MRAs for
architects in India. MRAs could facilitate
the mobility of architects, both in India
and abroad. They would allow Indian
architects to have their qualifications
recognised abroad, making it easier for
them to work in international markets. At
the same time, MRAs would open up the
domestic market to foreign architects on
reciprocal terms, encouraging knowledge
exchange and higher standards of
service delivery. By entering into MRAs

India’s Services Sector: Insights on Regulatory Regime in Professional Services 90
with their foreign counterpart, the CoA
could streamline the recognition of
qualifications in architectural and allied
services, benefiting both Indian and
foreign professionals.
5.2.4 Engineering Services
Regulatory framework for engineers involved in
construction and related activities
Recognition as Allied Professionals
#1
#2
(i) Regulatory framework for engineers
involved in construction and related
activities 
Establishing a central statutory framework
for engineers engaged in construction and
infrastructure related activities could help
enforce minimum standards, prescribe a
code of ethics, and introduce mechanisms
for accountability. Such a framework would
be particularly valuable in areas involving
public safety. Therefore, establishing a
comprehensive regulatory framework
would help enforce minimum standards and
introduce mechanisms for accountability.
Such a framework would improve structural
safety, enhance public confidence, and
support the professionalisation of these
services in India.
(ii) Recognition as Allied Professionals
Recognising architects and engineers as
allied professionals could provide a balanced
approach to regulating both professions,
particularly in view of their areas of overlap.
Such recognition would allow each of these
professionals to continue operating within
their respective domains of expertise, while
also engaging in activities that overlap.
Certain international practices provide
useful guidance on governance of such
professionals. For example, the Architects
Act, 1991 and the Professional Engineers
Act, 1991, of Singapore, both mutually
recognise the two professions as allied
and clearly define their respective scope
of practice. Section 2 of the Architects Act,
1991, recognises professional engineers
as allied professionals, while section 2
of the Professional Engineers Act, 1991,
extends the same recognition to architects.
Notably, neither framework prevent allied
professionals from working within their
respective domains, even where there may
be some functional overlaps, so long as
such overlaps do not form a substantial part
of the services rendered by the other. This
model demonstrates how regulatory clarity
can foster collaboration while preserving
professional boundaries.
Such international frameworks provide
useful guidance on how allied professions
can be encouraged to work in harmony
and alignment, while upholding the distinct
responsibilities and expertise that each
profession contributes.

India’s Services Sector: Insights on Regulatory Regime in Professional Services91
5.2.5 Healthcare and Allied Healthcare Services
Facilita te the timely
implementa tion of the
National Exit T est
Full Oper ationaliza tion of the
NCAHP A ct, 20 21 and Skilling
of Allied Pr ofessionals
Streamline multi-le vel
regula tory
governanc e of allied
health servic es
Streamline lic ensing
pathways for int ernational
healthcar e practitioners
Enable int erstate license
portability f or
healthcar e professionals
Pursue Mutual R ecognition
Agreements (MRAs )
(i) Facilitate the Timely Implementation
of the National Exit Test
The National Exit Test (NExT), as mandated
under the NMC Act, the NDC Act, and
the NCISM Act, may be implemented
expeditiously to standardise competency
assessments for medical graduates and
ensure a transparent, merit-based licensure
process across systems of medicine. Its
enforcement would also strengthen the
credibility of Indian medical graduates
both domestically and internationally.
(ii) Streamline Multi-level Regulatory
Governance of Allied Health Services
To support more effective harmonisation
across regulatory bodies, particularly in
areas such as AYUSH, there may be merit
in enhancing inter-ministerial coordination
and formalizing a clear demarcation of
roles among the Ministry of AYUSH, NCISM
and the state-level authorities to ensure
uniform standards, streamline decision-
making and enable better compliance
across the country while respecting the
federal structures.
(iii) Enable interstate license portability
for healthcare professionals
To facilitate greater mobility of healthcare
professionals in underserved domestic
areas, a seamless system of license
portability may be adopted. In this
regard, operationalising a national license
registry supported by MRAs among state
councils could reduce administrative
barriers and promote workforce flexibility.
Under such MRAs, state councils
would mutually recognise each other’s
registration decisions, allowing
professionals licensed in one state to
practice in another without duplicative
processes. An automatic approval route
may streamline licensure across states,
eliminating the need for repeated state
registrations and obtaining No Objection
Certificates. Additionally, the use of
digital technologies may support efficient
verification, enhance outreach and enable
timely deployment of medical and allied
health professionals where they are needed
the most.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 92
(iv) Full Operationalisation of the
NCAHP Act, 2021 and Skilling of Allied
Professionals
The full and timely implementation of
the NCAHP Act, 2021 may contribute
to standardization of education and
governance for allied health professionals,
ultimately enhancing accountability
and availability of qualified healthcare
professionals. Further, the adoption of a
comprehensive skilling framework for allied
health professionals in the essential care
industry will enable aspiring professionals
to fully capitalize on the growing
opportunities within the healthcare
industry. This reform is particularly timely
given India’s demographic dividend, which
presents a unique opportunity to our
domestic workforce.
The Union Budget 2026-27, reinforces this
focus by announcing dedicated efforts to
upgrade and add new the AHP institutions
with an aim to add 100,000 AHPs over
the next 5 years and implement NQSF
aligned programmes to train multiskilled
caregivers.caregivers.
(v) Streamline licensing pathways for
international healthcare practitioners
While the current health regulatory
legislations recognise foreign qualifications,
there is a need to explicitly establish clear
and harmonised licensing pathways,
including temporary or conditional licenses
for foreign-trained health professionals
across medical, nursing, dental, allied health,
and Indian systems of medicine fields.
Developing standardised, transparent
evaluation processes and a centralised
digital portal for managing these licenses
may facilitate the timely integration
of qualified international practitioners,
support workforce flexibility, and uphold
high standards of care and accountability.
(vi) Pursue Mutual Recognition
Agreements (MRAs)
The relevant regulatory authorities for
medical, dental, veterinary, paramedical,
nursing and midwifery, and physiotherapy
services could proactively negotiate MRAs
with their international counterparts to
ensure the recognition of professional
qualifications in these respective fields
and their allied services. This would
improve mobility for Indian professionals
across these sectors and also open up the
domestic market to international talent on
reciprocal terms.

India’s Services Sector: Insights on Regulatory Regime in Professional Services93
Figure 10. Snapshot of the four-pronged strategy and sector-specific insights
Continuous Professional
Development for
Professionals
Elevate professional
services within the
services value chain
Adoption of best
practices in professional
services
Advance the emerging
trends in professional
services
Four-pronged
Strategy
Sector-specific Insights
Recognition of
Legal Professionals
other than
Advocates
Regulatory
Harmonization and
Clarity
Professional
Mobility
Revisit Advertising
Norms
Modernize Legal
forms of Practice
Skilling of Allied
Legal Professionals
Pursue Mutual
Recognition
Agreements
(MRAs)
Enhance the
regulatory
oversight and
skilling of
bookkeeping
professionals
Phased
Accreditation
Pathways for
Foreign
Professionals
Professional
Examination for
Licensing of
Architects
Streamlined
registration
mechanism
Permit a Wider
Range of Legal
Structures
Regulatory
framework for
landscape
architects
Pursue MRAs
Regulatory
framework for
engineers involved
in construction
and related
activities
Recognition as
Allied
Professionals
Facilitate the
implementation of
the National Exit
Test
Streamline multi-
level regulatory
governance of allied
health services
Enable interstate
license portability
Fully operationalize
the NCAHP Act,
2021 and skilling of
allied health
professionals
Streamline licensing
pathways
Pursue MRAsLegal
Services Accounting,
Auditing, and
Bookkeeping
Services Architectural
Services Engineering
Services Health and
Allied Health
Services

India’s Services Sector: Insights on Regulatory Regime in Professional Services 94
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The Institute of Cost and Works Accountants of India. (2012, January 19). ICWAI gets its name
changed to ICAI and its members to use ACMA and FCMA [Press release]. https://icmai.in/
upload/Institute/Press_release/Press_Release_190112.pdf
Kaushik, M. (2025, July 30). Advertising guidelines for CAs under revision. Financial Express.
https://www.financialexpress.com/business/industry-advertising-guidelines-for-cas-under-
revision-icai-president-charanjot-singh-nanda-3930665/
Reforms in Urban Planning Capacity in India. 2021. New Delhi: NITI Aayog. https://www.niti.
gov.in/sites/default/files/2021-09/UrbanPlanningCapacity-in-India-Annexures-16092021.pdf
India Employment Report 2024: Youth Employment, Education and Skills. International Labour
Organisation.

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Singha, Rajdeep, and K Gayithri. Government Policy and Performance: A Study of Indian
Engineering Industry. Institute for Social and Economic Change.
World Health Organisation (WHO). (2024). Health practitioner regulation: Design, reform and
implementation guidance. https://www.who.int/publications/i/item/9789240095014
International Labour Organisation. (2023, May 12). Nurses and midwives: overworked,
underpaid, undervalued?. https://ilostat.ilo.org/nurses-and-midwives-overworked-underpaid-
undervalued/
Kumar, R and Rodney, T. (2021). Advancing Nursing Practice in India Historical Lessons from
the United States. Indian Journal of Continuing Nursing Education, 22(2): pp 115-122.
Tseng, P.-E., & Wang, Y.-H. (2021). Deontological or Utilitarian? An Eternal Ethical Dilemma in
Outbreak. International Journal of Environmental Research and Public Health, 18(16), 8565.
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National Financial Reporting Authority of India (NFRA). 2024. Opinon of Ld Solicitor General
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Bar & Bench. SILF urges BCI to give statutory recognition, extend attorney-client privilege to
Indian General Counsel. Retrieved from https://www.barandbench.com/news/silf-urges-bci-
to-give-statutory-recognition-extend-attorney-client-privilege-to-indian-general-counsel.
Economic Times. GCAI Conference highlights need for recognition of in-house counsels in
India. Retrieved from https://legal.economictimes.indiatimes.com/news/corporate-business/
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Financial Reporting Council. Third country auditors. Available at: https://www.frc.org.uk/
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centers-gccs-story-in-2025-blog/

India’s Services Sector: Insights on Regulatory Regime in Professional Services 98
Legislations
1. The Advocates Act, 1961
2. The All India Council for Technical Education Act, 1987
3. The All India Council for Technical Education (Constitution and Functions of National
Board of Accreditation) Regulations, 2005
4. The Architects Act, 1972
5. The Architects (Professional Conduct) Regulations, 1989
6. The Bar Council of India Rules, 1975
7. The Bar Council of India Rules for Registration and Regulation of Foreign Lawyers and
Foreign Law Firms in India, 2022
8. The Chartered Accountants Act, 1949
9. The Chartered Accountants Regulations, 1988
10. The Clinical Establishments (Central Government) Rules, 2012
11. The Clinical Establishments (Registration and Regulation) Act, 2010
12. The Companies (Accounting Standard Rules), 2021
13. The Companies (Audit and Auditors) Rules, 2014
14. The Companies (Registration of Foreign Companies) Rules, 2014
15. The Companies Act, 2013
16. The Company Secretaries Act, 1980
17. The Company Secretaries Regulations, 1982
18. The Consumer Protection Act, 2019
19. The Cost Accountants Act, 1959
20. The Cost and Works Accountants Regulations, 1959
21. The Council of Architecture (Minimum Standards of Architectural Education) Regulations,
2020
22. The Dental Council of India (BDS Course) Regulations, 2017
23. The Dental Council of India (Code of Ethics) Regulations, 2018
24. The Dental Council of India Screening Test Regulations, 2009
25. The Dentists Act, 1948
26. The Foreign Exchange Regulation Act, 1973

India’s Services Sector: Insights on Regulatory Regime in Professional Services99
27. The Foreign Medical Graduate Licentiate Regulations, 2021
28. The Goods and Services Tax Act, 2017
29. The Gujarat Professional Civil Engineers Act, 2006
30. The Homeopathy Central Council Act, 1973
31. The ICWAI (Amendment) Act of 2011
32. IFSCA (Book-keeping, Accounting, Taxation and Financial Crime Compliance Services)
Regulations, 2024.
33. The Income Tax Act, 2025
34. The Indian Constitution, 1950
35. The Indian Dental Association Code of Ethics, 2014
36. The Indian Medical Council Act, 1956
37. The Indian Medicine Central Council Act, 1970
38. The Indian Medicine Central Council (Minimum Standards of Education in Indian
Medicine) Amendment Regulations, 2019
39. The Indian Nursing Council Act, 1947
40. The Indian Nursing Council (ANM to GNM) Two-year Bridge Program Regulations, 2024
41. The Indian Nursing Council (Nurse Practitioner Midwifery (NPM) Educator Program
Curriculum) Regulations, 2020
42. The Indian Partnership Act, 1932
43. The Indian Veterinary Council Act, 1984
44. The Indian Veterinary Council (Professional Conduct, Etiquette and Code of Ethics)
Regulations, 1992
45. The Karnataka Professional Civil Engineers Bill, 2024
46. The Limited Liability Partnership Act, 2008
47. The Maintenance of Standards of Medical Education Regulation, 2023
48. The National Commission for Allied and Healthcare Professions Act, 2021
49. The National Commission for Homoeopathy Act, 2020 (NCHA, 2020)
50. The National Commission for Indian System of Medicine Act, 2020 (NCISM Act)
51. The National Dental Commission (NDC) Act, 2023
52. The National Dental Commission Rules, 2024
53. The National Financial Reporting Authority Rules, 2018.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 100
54. The National Medical Commission Act, 2019 (NMC Act)
55. The National Nursing and Midwifery Commission (NNMC) Act, 2023
56. The National Nursing Midwifery Commission Rules, 2024
57. The NCH (National Examinations in Homeopathy) Regulations, 2023
58. The NCISM (Minimum Standard of Undergraduate Siddha Education) Regulations, 2022
59. The NCISM (Minimum Standard of Undergraduate Sowa-Rigpa Education) Regulations, 2022
60. The NCISM (Minimum Standards of Undergraduate Ayurvedic Education) Regulations, 2022
61. The NCISM (Minimum Standards of Undergraduate Unani Education) Regulations, 2022
62. The NMC (Compulsory Rotating Medical Internship) Regulations, 2021
63. The NMC National Exit Test Regulations, 2023
64. The NMC Registered Medical Practitioner (Professional Conduct) Regulations, 2023
65. Post Basic Diploma in Cardiothoracic Specialty Nursing - Residency Program Regulations, 2023
66. The Postgraduate Medical Education Regulations, 2023
67. The Practitioners of Indian Medicine (Standards of Professional Conduct, Etiquette and Code of
Ethics) Regulations, 1982
68. The Recognition of Medical Qualification Regulations, 2023
69. The Registration of Medical Practitioners and License to Practice Medicine Regulations, 2023
70. The Special Economic Zones Act, 2005
71. The Telemedicine Practice Guidelines, 2020
72. The University Grants Commission (Recognition and Grant of Equivalence to Qualifications
Obtained From Foreign Educational Institutions) Regulations, 2025
73. The VCI Minimum Standards of Veterinary Education (Bachelor of Veterinary Science and Animal
Husbandry - Degree Course) Regulations, 2016

India’s Services Sector: Insights on Regulatory Regime in Professional Services101
Annexure I
Country Positions in
Select Jurisdictions

in Professional Services

India’s Services Sector: Insights on Regulatory Regime in Professional Services 102
This annexure examines the regulatory
positions adopted by select foreign
jurisdictions in the field of Professional
Services vis-à-vis the analysis undertaken
in chapter 2 of this report. It explores how
regulatory issues are addressed in these
jurisdictions, including the rights, obligations
and limitations arising therein. These
jurisdictions have been identified based on
two primary factors:
(i) Economic comparability with India, or
(ii) Notable reforms undertaken in
the identified areas to improve ease of
doing business and liberalise regulatory
framework.
It is important to note that this report
references and analyses legal provisions
from foreign jurisdictions based on publicly
available legal texts, secondary sources,
and/or translations thereof. The authors of
this report are not licensed to practice law
in these jurisdictions. While reasonable care
has been taken in interpreting and presenting
the relevant legal frameworks, the accuracy
and completeness of this analysis cannot
be independently verified or guaranteed.
Readers are, therefore, strongly encouraged
to consult qualified legal professionals
licensed in the relevant jurisdiction(s) for
authoritative legal guidance.
1. Legal Services
This section examines the regulatory
framework governing legal services in
select Commonwealth jurisdictions,
namely, Singapore, South Africa and the
United Kingdom. These jurisdictions have
been chosen either because they represent
emerging economies with regulatory
concerns comparable to India, such as
South Africa or because they maintain a
strong connection with the Indian legal
market and are regarded as high-ambition
models, such as Singapore and England
and Wales in the United Kingdom.
This section further considers the
commitments undertaken by these
jurisdictions under GATS, as the extent of
such commitments often reflects domestic
regulatory priorities and sensitivities within
the legal services sector. In this regard,
Singapore has not undertaken any specific
commitments in legal services under GATS.
By contrast, South Africa and the United
Kingdom have undertaken commitments
in relation to two categories of legal
services: (a) advisory services in foreign
and international law, and (b) domestic law
only.
(a) Recognition of Legal Professionals
Singapore: In Singapore, legal
professionals are regulated under the
Legal Profession Act, 1966 and its
related rules such as Legal Profession
(Continuing Professional Development)
Rules, 2012 or Legal Profession (Foreign
Practitioner Examination) Rules, 2011
(collectively, LPAS). Here, lawyers are
broadly categorized as Singapore-qualified
lawyers, foreign lawyers authorised to
practice Singapore law or foreign law and
regulated non-practitioners.
Singapore-qualified lawyers comprise
“Advocates” and “Solicitors” who enjoy
exclusive right to appear and plead
before all courts of justice in Singapore
(Legal Profession Act, 1966, section
Annexure I
Country Positions in Select Jurisdictions in
Professional Services

India’s Services Sector: Insights on Regulatory Regime in Professional Services103
29(1)). However, in practice, many lawyers
specialise either as litigators or as solicitors
and do not appear in courts (Charles Lim
Aeng Cheng, Legal Systems in ASEAN –
Singapore).
Foreign lawyers may practise both
Singapore law and/or foreign law including
international arbitration based on the
provisions of the LPAS. For example, legal
service providers with a Qualified Foreign
Law Practice (QFLP) licenses may practice
in permitted areas of Singapore law,
excluding constitutional and administrative
law, conveyancing, criminal law, family law,
succession law, and trust law.
The regulatory framework also permits the
participation of non-lawyer professionals
and foreign lawyers who are not registered
to practice Singapore law. Organisations
seeking to appoint such individuals as
directors, partners, shareholders, or profit-
sharers must obtain approval from the Legal
Services Regulatory Authority (LSRA) and
register them as regulated non-practioners
(Legal Profession Act, 1966, section 36G).
In-house counsels, whether Singapore-
qualified or foreign-qualified, may provide
legal advice exclusively to their employing
entity. However, they are not authorised to
appear before courts, quasi-judicial bodies,
or tribunals, nor may they attest documents
that are legally required to be attested by
an advocate and solicitor (Legal Profession
Act, 1966, section 36(ec)).
South Africa: The Legal Practice Act 28
of 2014 governs the legal profession in
South Africa. It defines "legal practitioners"
as "advocates or attorneys admitted and
enrolled as such" (Legal Practice Act 28 of
2014, section 1). Under Section 33 of the
Act, only legal practitioners are generally
permitted to appear before a court or
tribunal, draft legal instruments, or execute
documents intended for use in civil or
criminal proceedings (Legal Practice
Act 28 of 2014, section 33). As a result,
other professionals, including Chartered
Accountants, are not authorised to provide
legal services within the scope reserved for
legal practitioners in South Africa.
South Africa maintains the traditional
distinction between attorneys and
advocates. Attorneys may deal directly
with clients and are authorised to maintain
trust accounts. They handle both litigious
and non-litigious matters, including dispute
resolution, legal drafting, regulatory advice,
and compliance auditing. Advocates, by
contrast, are litigation specialists who do
not engage directly with the public. Instead,
they are briefed by attorneys to represent
clients in court. Notably, while foreign legal
practitioners are not permitted to offer
general legal services, they may participate
in arbitration proceedings within South
Africa. (Jonathan Klaaren, Tracy-Lynn Field
& Jacques Mahler-Coetzee, 2021).
Although advocates are generally
prohibited from rendering legal services
directly to the public, they may do so under
the conditions specified in section 34(2)
of the Legal Practice Act, provided they
maintain a trust account. Historically, the
absence of direct client relationships has
been regarded as a defining characteristic
of advocacy practice. The Legal Practice
Act 28 of 2014 further mandates that all
legal practitioners, both attorneys and
advocates, must be registered with, and are
subject to the regulatory and disciplinary
authority of, the Legal Practice Council
(LPC).
England: The Legal Services Act, 2007,
under section 12, lays down certain
“reserved legal activity”, which are a set
of six specific legal services activities that
only authorised persons (or those who are
exempt) can carry out. The scope of these

India’s Services Sector: Insights on Regulatory Regime in Professional Services 104
activities is set out in Schedule 2 of the
Legal Services Act. These reserved legal
activities include:
a. Right of Audience: This includes the
right to appear before and address a court,
call and examine witnesses etc.
b. Conduct of Litigation: This includes
issuing of proceedings before any court
in England and Wales, prosecuting
and defending those proceedings and
performing any ancillary functions in
relation to those proceedings.
c. Reserved Instrument Activities:
This includes preparing any instrument
of transfer or charge for the purposes of
registration of land and preparing any
other instrument relating to real or personal
estate.
d. Probate activities: Involves preparing
any probate papers.
e. Notarial Activities.
f. Administration of oaths.
Unlike the legal landscape in India, various
legal professionals in the UK have varying
right of audience/ right to appear before
courts. For example, solicitors have
automatic rights of audience in lower
courts like Magistrates' Courts and County
Courts and in tribunal hearings. However,
they cannot automatically appear in higher
courts such as the Crown Court, High Court,
or the Court of Appeal (Taylor, Ladrowska,
Ijaodola & Higginson, 2024). Further,
certain individuals can carry out reserved
legal activities without formal authorisation
if they fall under specific exemptions. For
example, trainees or paralegals assisting
authorised lawyers in certain non-family
court hearings may be exempt. Similarly,
the right to conduct litigation (managing
legal proceedings) can be exercised
without authorisation if granted by a court,
permitted by law, or held by a party to the
case (Legal Services Board, Reserved Legal
Activities).
It must be noted that not all legal work in
the UK is regulated, only reserved activities
require authorisation, while non-reserved
activities can be performed freely. The full
list of exemptions is detailed in Schedule
3 of the Legal Services Act, 2007. They
include providing general legal advice,
representation in legal disputes (provided
they do not fall under the six reserved legal
activities). In this context, legal services,
such as advice on the legal aspects of tax
and company law, and work on probate and
succession are performed by Chartered
accountants. Activities like mediation or
judicial roles are also excluded from this
definition.
Under section 14 read with section 181 of the
Legal Services Act, it is a criminal offence
to perform a reserved legal activity without
proper authorisation, or falsely claim to be
a barrister (or use a title suggesting this).
(b) Regulation of Foreign Lawyers & Law
Firms
Singapore: A “foreign lawyer” under the
LPAS means an individual who is duly
authorised or registered to practise law in
a state or territory other than Singapore
by the competent regulatory authority
of that jurisdiction (Legal Profession Act
1966, section 2). A “foreign law practice”
means a law practice (including a sole
proprietorship, a partnership or a body
corporate, whether with or without limited
liability) providing legal services in any
foreign law in Singapore or elsewhere,
but excludes Singapore law practice.
The regulation, licensing and supervision
of foreign lawyers and law firms are
overseen by the Legal Services Regulatory
Authority (LSRA) under the Ministry of Law
(Singapore - Licensing Requirements for

India’s Services Sector: Insights on Regulatory Regime in Professional Services105
Professional Services, U.S. Department of
Commerce, 2024).
Foreign-qualified lawyers who pass the
Foreign Practitioner Examinations (FPE)
may register with the LSRA as a foreign
practitioner under section 36B of the
LPAS and become eligible to practise both
Singapore law and foreign law. Additionally,
a foreign lawyer may apply for either a full
registration or restricted registration with
the Singapore International Commercial
Court (SIIC) (Legal Profession Act 1966,
section 36P).
Foreign lawyers granted full registration
may appear and plead in relevant
proceedings before the Singapore
International Commercial Court (SICC) and
the Court of Appeal, represent parties in
such proceedings, and provide legal advice
and documentation support relating to
those proceedings. By contrast, lawyers
granted restricted registration may only
make submissions and provide advice on
matters of foreign law permitted by the
SICC or the Court of Appeal, in accordance
with the Rules of Court. The SICC Registry
maintains a registry of foreign lawyers who
are granted full or restricted registration
under Section 36P of the LPAS and
relevant rules (RFL) (Legal Profession
(Representation in Singapore International
Commercial Court) Rules 2014).
Additionally, as of 1 November 2017, a
foreign lawyer registered under section
36P of the LPAS and listed on the RFL
is exempt from requiring a work pass in
Singapore, on a conditional basis. Before
entering Singapore, such persons must
be engaged either as an employee or self-
employed to perform a specified activity
as defined under section 36P. Upon arrival
and before commencing work, such person
must notify the Ministry of Manpower’s
Controller of Work Passes about the
nature and duration of the activity via an
e-Notification. The exemption applies for
up to 90 days per year, extendable at the
Controller’s discretion (Employment of
Foreign Manpower (Work Pass Exemptions
– Specified Activities) (Amendment)
Notification 2017).
Further, legal firms with a licensed Foreign
Law Practice (FLP) may offer the full
range of legal services in foreign law and
international law, but cannot practice
Singapore Law, except in the context of
international commercial arbitration or in
relation to the SICC, through certain types
of registered lawyers (Legal Profession Act
1966, section 172). To practice Singapore
law, Foreign Law Practices require a QFLP,
a Joint Law Ventures (JLVs) or Formal Law
Alliances (FLAs) with a Singapore Law
Practices (SLPs) (Singapore - Licensing
Requirements for Professional Services,
U.S. Department of Commerce, 2024).
The QFLP regime permits foreign firms to
practise in specified areas of Singapore law
while excluding sensitive practice areas
such as constitutional and administrative
law, conveyancing, criminal law, family law,
succession law, and trust law. A JLV is a
collaboration between a FLP and a SLP,
which may be constituted as a partnership
or company. The Director of Legal Services
in LSRA will consider all the relevant
circumstances including the proposed
structure and its overall suitability to
achieve the objectives for which Joint law
Ventures are permitted to be established.
South Africa: The Legal Practice Act
28 of 2014 (LPA) permits only persons
admitted and enrolled under the Act to
practise as legal practitioners in South
Africa. Under section 24(2)(b), admission
is generally restricted to (a) a citizen; or (ii)
a permanent resident of South Africa. As
legal practitioners in South Africa, a person

India’s Services Sector: Insights on Regulatory Regime in Professional Services 106
can take part in litigation, appear in court
and carry out conveyancing transactions.
To qualify as a legal practitioner in South
Africa, persons mentioned under section
24(2)(b) must satisfy the requirements for
a law degree obtained in a foreign country,
which is equivalent to a South African
LLB degree and must be recognised by
the South African Qualifications Authority
established by the National Qualifications
Framework Act, 2008 (Act N67 of 2008).
They must also comply with the other
requirements relating to vocational
training or community service and pass the
competency-based admission examination
(Legal Practice Act 28 of 2014, section 26).
Persons from Swaziland, Namibia, Lesotho
and the former Transkei, Bophuthatswana,
Venda and Ciskei states are excepted from
the above requirement.
Therefore, non-citizens and non-permanent
residents cannot be admitted and enrolled
as legal practitioners in South Africa.
However, the LPA retains a pathway for
admission and enrolment of foreign legal
practitioners to appear in courts and to
practise as legal practitioners in South
Africa (Legal Practice Amendment Act,
No. 16 of 2017, section (a)). As per section
24(3), the Minister of Justice, the Minister
of Trade and Industry, and the South
African Legal Practice Council may make
regulations in respect of admission and
enrolment to determine the right of foreign
legal practitioners to appear in courts in
South Africa.
While the LPA is silent about foreign law
firms needing license to operate in South
Africa, a number of foreign law firms
including Dentons, Hogan Lovells, Clyde &
Co, Norton Rose Fulbright and Linklaters
have set up offices in South Africa (Dale
Verster, 2014). However, foreign lawyers
who are not admitted under the LPA are
generally limited to advising on foreign
law, international law, and international
arbitration matters.
England: A foreign qualified lawyer or an
overseas student may qualify either as
solicitors or barristers in England and Wales.
Foreign lawyers seeking qualification as
solicitors must register with the Solicitors
Regulations Authority as per section 89
of the Courts and Legal Services Act
1990, pass a 2-part Solicitors Qualifying
Examination (SQE) conducted by the
Solicitors Regulation Authority (SRA), hold
a degree in any subject or an equivalent
qualification (such as an apprenticeship)
or work experience, and must satisfy the
Solicitor Regulation Authority's (SRA)
character. Overseas candidates are
generally required to complete two years
of Qualifying Work Experience (QWE),
although fully qualified foreign lawyers
may be exempt from this requirement
depending on their qualifications and
professional standing (How to Become a
Solicitor: A Guide for International Lawyers,
2025).
Foreign-qualified lawyers wishing to
practise as barristers must apply to transfer
to the Bar of England and Wales through
the Bar Standards Board (BSB) (Bar
Standards Board, Transferring Lawyers,
2025). Foreign-qualified lawyers may
be granted exemptions from some or all
Bar training requirements based on their
qualifications and experience. The BSB will
assess the application and, if exemptions
are granted, will specify which assessments
must be completed. Even with exemptions,
applicants may still need to undertake
pupillage or work-based learning
and complete the Professional Ethics
assessment during that period, unless
specifically exempted (Bar Standards
Board, Transferring Lawyers, 2025).

India’s Services Sector: Insights on Regulatory Regime in Professional Services107
(c) Permissible Forms of Establishment
Singapore: Singapore’s LPA provides
significant flexibility regarding the
organisational structure of legal
establishments. The LPA defines “law
practice entity” to include: (a) a Singapore
law practice; (b) a Joint Law Venture; (c)
a Formal Law Alliance; (e) a foreign law
practice which is a member of a Formal
Law Alliance; (f) a Qualifying Foreign
Law Practice; (g) a licensed foreign law
practice; or (h) a representative office
(Legal Profession Act 1966, section 2).
Singapore law practice includes (a) a law
firm; (b) a limited liability law partnership;
or (c) a law corporation. A law firm is
defined as a partnership, or a practice of
a solicitor who practises on his or her own
account. Similarly, a Joint Law Venture can
be a limited liability company or a private
company (Legal Profession Act 1966,
section 169).
South Africa: The Legal Practice Act 28 of
2014 permits legal services to be provided
through a commercial juristic entity. Under
section 34(7) of the Legal Practice Act,
2014, such an entity may be established to
conduct a legal practice, provided that its
shareholding, partnership or membership
comprises exclusively of attorneys.
Therefore, while a legal practice may be
set up as a corporation, it must be a limited
liability company with a separate legal
entity, distinct from its owners, and can
own property, enter contracts, and incur
debts in its own name.
England: In England and Wales, legal
practices may be established through a
variety of organisational forms, including
partnerships, LLPs and limited companies
(Solicitors Regulation Authority, SRA
Authorisation of Firms Rules, 2023).
A distinctive feature of the regulatory
framework is the Alternative Business
Structure (ABS) regime, which permits
non-lawyers to own and manage law firms
authorised to carry on one or more of
the reserved legal activities regulated by
the LSA 2007. A firm may also qualify as
ABS where non-lawyers hold ownership
interests, exercise managerial control or
another entity participates in the firms
governance. A firm may also be treated
as ABS where at least 10% of that body is
controlled by non-lawyers. This framework
has the potential to encourage new
investment from different markets (Law
Society of England and Wales, Alternative
Business Structures, 2023).
(d) Continued Professional Development
(CPD)
Singapore: The Legal Profession
(Continuing Professional Development)
Rules, 2012 mandates CPD requirements
for both domestic and foreign lawyers
(Legal Profession (Continuing Professional
Development) Rules 2012, S 115/2012).
South Africa: The Law Society of South
Africa (LSSA) mandates attorneys to
comply with CPD requirements under
its Mandatory Continuing Professional
Development (MCPD) Policy (Professional
Body Recognition and Professional
Designation Registration; Evaluation
Report, clause 3.4, 2015).
England: Under section 3.3 of the SRA
Code of Conduct for Solicitors, Registered
European Lawyers, Registered Foreign
Lawyers, and Registered Swiss Lawyers,
solicitors and lawyers must maintain their
competence to carry out their role and
keep professional knowledge and skills up
to date. Therefore, solicitors and registered
lawyers, under the Solicitors Regulation
Authority, need to go through mandatory
continuing competence (SRA Code of
Conduct for Solicitors, RELs and RFLs,
section 3.3).

India’s Services Sector: Insights on Regulatory Regime in Professional Services 108
2. Accounting, Auditing and Bookkeeping
Services
This section presents the regulatory
framework governing accounting and
related services in the United Kingdom,
Singapore and Canada. These jurisdictions
were selected as they are common law
jurisdictions with well-developed regulatory
frameworks for accountancy services and
have undertaken commitments in this
sector under GATS.
(a) Restrictions on foreign participation
and practice rights:
United Kingdom: Foreign accountants and
auditors seeking to render services in the
United Kingdom are subject to a number
of regulatory restrictions. Only individuals
and firms holding a recognized UK audit
qualification awarded by Recognised
Qualifying Bodies (RQBs) such as the
ICAEW, ACCA, or AIA may be appointed
as auditors of UK companies and certain
other legal entities. Foreign qualifications
must be recognized as “equivalent,” and
in most cases, third country auditors may
be required to pass an aptitude test to
demonstrate competence in UK law and
audit practice. Even with equivalence, there
are requirements for local registration
and compliance with stringent ethical,
independence, and reporting standards.
Additionally, foreign audit firms may face
ownership and management restrictions,
as the majority of partners or directors,
must be “approved” under UK regulations.
Bookkeeping services in the UK are
regulated indirectly through the anti-
money laundering framework. Individuals
and entities providing bookkeeping or
accountancy services are subject to
supervision under the Money Laundering,
Terrorist Financing and Transfer of Funds
(Information on the Payer) Regulations
2017.In accordance with Regulation 7(c),
all persons providing bookkeeping services
are subject to supervision under the anti-
money laundering (AML) regime (Money
Laundering Regulations 2017, Reg. 7(c)).
Further, Regulation 26(4) and (5) stipulates
that any individual or entity offering these
services must be approved by the relevant
supervisory authority (Money Laundering
Regulations 2017, Reg. 26(4) & (5)).
Singapore: Only individuals or firms
registered as public accountants with the
Accounting and Corporate Regulatory
Authority (ACRA) are permitted to conduct
statutory audits and issue audit opinions on
financial statements in Singapore. Overseas
qualifications are not automatically
recognized. Such professionals must
meet Singapore’s registration, licensing,
and professional standards, including
local residency, experience, fit-and-
proper criteria, and comply with the Code
of Professional Conduct and Ethics as
prescribed by the Institute of Singapore
Chartered Accountants (ISCA). Audit firms
must also be approved accounting entities
under ACRA.
Singapore does not maintain a separate
statutory licensing framework for
bookkeepers. However, individuals who
provide bookkeeping services as part
of public accountancy services and
must comply with the Accountants Act
2004. (Accountants Act 2004, Sec. 10).
Where bookkeeping forms part of public
accountancy, the providers must be
registered as public accountants with the
Accounting and Corporate Regulatory
Authority (ACRA) under the Accountants
Act 2004. Where bookkeeping is offered
as part of corporate service functions,
the Corporate Service Providers Act 2024
requires entities to register with ACRA,
satisfy fit-and-proper requirements,

India’s Services Sector: Insights on Regulatory Regime in Professional Services109
and comply with ongoing anti-money
laundering and counter-terrorism financing
(AML/CFT) obligations (Corporate Service
Providers Act 2024).
ACRA is the primary supervisory
authority responsible for regulating
public accountants, accounting entities,
and corporate service providers. It
enforces statutory compliance under the
Accountants Act 2004 and the Corporate
Service Providers Act 2024.
Canada: In Canada, public accounting and
auditing are regulated at the provincial and
territorial level. Only individuals registered
with a provincial or territorial Chartered
Professional Accountants (CPA) body are
authorized to independently practice, use
professional designations, or sign audit
reports in Canada. Overseas qualifications
are not directly recognized; internationally
qualified accountants must generally
either enter mutual recognition pathways
(if available) or complete substantial
equivalency requirements, including
Canadian ethics, tax, and law courses,
and pass the Common Final Examination
(CFE). In addition, candidates are typically
required to have a university degree,
satisfy at least 30 months of recognized
practical training, and fulfil audit-specific
experience such as 1,250 chargeable
assurance hours and 625 audit hours within
five years before application, subject to
approval by the relevant CPA authority.
Public accounting and auditing licenses are
strictly provincially regulated, which means
licensing requirements and permissible
services may vary, and foreign-trained
professionals must comply with local
registration and professional standards in
each jurisdiction (CPABC).
By contrast, bookkeeping is not a regulated
profession in Canada. There is no statutory
licensing, registration, or certification
requirement for individuals practising
as bookkeepers. Foreign individuals or
firms may enter the market and offer
bookkeeping services without seeking
prior approval or professional recognition.
If a foreign bookkeeper wishes to establish
a local presence, they must comply with
general business registration requirements
under federal or provincial corporate law,
including obtaining a business number for
tax purposes. Immigration laws may apply
to foreign nationals who wish to work in
Canada physically, but these are distinct
from professional licensing.
There is no statutory supervisory body
for bookkeepers. Voluntary associations
like Certified Professional Bookkeepers of
Canada (CPB Canada) offer membership
and certification, but participation
is voluntary. The Canada Revenue
Agency (CRA) enforces record-keeping
requirements under the Income Tax Act,
but these obligations apply to businesses,
not to the bookkeepers who assist them
(Business records for sole proprietorships
and partnerships).
(b) Regulatory oversight of accounting
and auditing services:
United Kingdom: Chartered Accountants
(CAs) in the United Kingdom are primarily
regulated by the Financial Reporting
Council (FRC), which also serves as the
authority for regulating auditors and setting
accounting standards (FRC, Supervision of
the accountancy profession). A prominent
professional body in this domain is the
Institute of Chartered Accountants in
England and Wales (ICAEW), which is
responsible for regulating its members and
member firms.
Chartered Secretaries, on the other hand,
are regulated by the Chartered Governance
Institute (CGI). This institute oversees the

India’s Services Sector: Insights on Regulatory Regime in Professional Services 110
professional standards, qualifications, and
conduct of Chartered Secretaries in the UK
(FRC).
Singapore: In Singapore, the regulation
of Chartered Accountants is shared
between two entities: the Accounting and
Corporate Regulatory Authority (ACRA)
and the Institute of Singapore Chartered
Accountants (ISCA). ACRA acts as the
national regulator for public accountants,
while ISCA is the designated professional
body responsible for awarding the
Chartered Accountant (CA) (Singapore)
designation (ACRA, Chartered Secretary).
Chartered Secretaries in Singapore are
primarily governed by the Companies Act
and ACRA. One key regulatory requirement
under this framework is that companies
must appoint a company secretary who
is a Singapore resident and possesses
adequate knowledge and experience to
discharge the responsibilities of the role
(ACRA and ISCA).
Canada: In Canada, Chartered Professional
Accountants (CPAs) are subject to both
provincial and national regulation. Each
province and territory have its own CPA
body, which holds the authority to grant
and regulate the CPA designation within
its jurisdiction. On the national level,
CPA Canada supports the profession by
promoting its interests and representing
Canadian CPAs domestically and
internationally (ACRA, Overview of ACRA).
Chartered Secretaries in Canada are
regulated by The Chartered Governance
Institute of Canada (CGIC), which
is a division of the global Chartered
Governance Institute (CGI). The CGIC is
entrusted with setting the professional
standards for Chartered Secretaries in
Canada, encompassing requirements
related to education, practical experience,
and ethical conduct (CPA provincial and
regional accounting bodies).
(c) Structured Continuing Professional
Development (CPD) for All Practitioners
United Kingdom: Professional bodies in
the UK mandate CPD through internal
regulations. Under the Continuing
Professional Development Regulations
2023 of the Institute of Chartered
Accountants in England and Wales (ICAEW),
all members, relevant persons, and firms
must undertake and record CPD annually,
including minimum hour requirements and
mandatory ethics training.
The Chartered Institute of Public Finance
and Accountancy (CIPFA) also requires
its chartered members to follow a CPD
scheme, based on international standards.
Other bodies, such as the Association of
Chartered Certified Accountants (ACCA),
Institute of Certified Public Accountants
(ICPA), and Chartered Accountants
Ireland, impose similar CPD obligations.
For instance, individuals recognised as
Responsible Individuals (RIs) for audit under
the Institute of Chartered Accountants in
Ireland must complete audit-specific CPD
as per the relevant audit regulations.
The Financial Reporting Council (FRC)
supervises professional accountancy
bodies and delegates CPD enforcement
to Recognised Supervisory Bodies
(RSBs). However, UK legislation such as
the Companies Act 2006 or tax statutes
does not impose CPD obligations on
all practitioners. Unregulated or non-
member practitioners (e.g., tax preparers
or bookkeepers unaffiliated with a
professional body) are not subject to any
statutory CPD requirements.
Singapore: The Accounting and Corporate
Regulatory Authority (ACRA) requires

India’s Services Sector: Insights on Regulatory Regime in Professional Services111
applicants seeking registration as public
accountants to complete a minimum of
40 Continuing Professional Education
(CPE) hours in the 12 months prior to
application, of which at least 30 hours must
be structured learning. Public accountants
must fulfil 120 CPE hours over a rolling
three-year period.
The Institute of Singapore Chartered
Accountants (ISCA) mandates 60 CPE
hours for Chartered Accountants within a
three-year rolling window, with at least 20
verifiable hours per year, including ethics
training. The Singapore Chartered Tax
Professionals (SCTP) require accredited
tax professionals to complete 30 hours of
CPE annually, which can also be calculated
over a three-year period. Chartered Valuer
and Appraiser (CVA) holders must fulfil 20
CPD hours each year, with subject-specific
requirements for core practice areas.
Canada: CPD requirements in Canada are
set at the provincial level by Chartered
Professional Accountant (CPA) bodies. For
instance, CPA Ontario requires members
to maintain professional competence by
completing a minimum of 120 CPD hours
in each rolling three-year cycle. This must
include at least 50% verifiable hours, four
hours of professional ethics, and a minimum
of 20 hours annually, with at least 10 being
verifiable.
(d) Centralized Audit Database or
Registry
United Kingdom: The United Kingdom
maintains a comprehensive statutory
framework governing the registration
and oversight of auditors. Under Part
42, Sections 1212–1224 of the Companies
Act 2006, statutory auditors are defined
as individuals or firms registered with a
Recognised Supervisory Body (RSB) and
authorised to conduct statutory audits.
The framework applies to both domestic
and third-country auditors, with further
regulations prescribed under the Statutory
Audit and Third Country Auditors
Regulations 2016.
Registration is a legally mandated pre-
required to conduct statutory audits.
Inorder to facilitate regulatory oversight
and transparency several registers are
maintained at the national level, including:
• Register of Statutory Auditors
and Audit Firms: Maintained under
the Companies Act 2006, listing
UK-registered auditors, their RSB
affiliations, and key individuals.
• Register of Third Country Audit
Entities: Required under the Statutory
Audit Directive (2006/43/EC), as
implemented through Sections 1242
and 1261 of the Companies Act, for non-
UK firms auditing UK-listed companies.
• PIE Auditor Register: Lists firms
authorised to audit Public Interest
Entities (PIEs) under FRC oversight.
• Local Auditor Register: Created by the
FRC’s Local Auditors (Registration)
Instrument 2015, listing auditors eligible
for public bodies in England.
These registers are overseen by the Financial
Reporting Council (FRC) and are publicly
accessible, notably through platforms
like the Audit Register. While there is no
central public registry of individual audit
engagements, audit reports are filed with
Companies House alongside company
accounts. Accordingly, transparency is
achieved through a combination of public
audit registers and statutory corporate
filings rather than through a singular
engagement-level database.
Singapore: In Singapore, audit firms
and public accountants are defined and
regulated under the Accountants Act

India’s Services Sector: Insights on Regulatory Regime in Professional Services 112
2004. Pursuant to Sections 10 and 18–21
of the Act, only individuals and entities
registered with the Accounting and
Corporate Regulatory Authority (ACRA)
are authorised to conduct statutory audits.
Singapore maintains a national Register
of Public Accountants and Accounting
Entities, which includes all approved audit
firms and licensed public accountants.
Registration is mandatory and publicly
accessible via ACRA’s online platform,
BizFile+. Applicants must meet statutory
requirements related to qualifications,
practical experience, continuing
professional education, and firm structure.
Although Singapore does not maintain a
single public registry of individual audit
reports or audit engagements, the public
registers of firms and accountants serve
as official sources for verification and
oversight. ACRA oversees registration,
compliance, and enforcement under the
statutory scheme.
Canada: Canada does not have a
centralized national registry of audit firms
or audit engagements. Audit regulation
is undertaken by provincial and territorial
Chartered Professional Accountant (CPA)
bodies, each of which defines and licenses
public accountants within its jurisdiction.
Accordingly, CPA bodies maintain provincial
registers of licensed public accountants
and firms within their jurisdiction. While
authorisation and disciplinary oversight
are provincial responsibilities, coordinated
through the unified CPA profession, there
is no federal statute or unified national
framework mandating a central audit
registry.
Certain national databases provide
information relevant to corporate entities
but do not function as audit registries. For
example:
• Statistics Canada’s Business Register
(BR) compiles economic data on legal
entities but unavailability audit-specific
information.
• Corporations Canada Database
provides corporate details for federally
incorporated entities but omits audit
information.
Similarly, securities regulation under the
Canadian Securities Administrators (CSA)
requires disclosure of auditor details in
filings submitted via SEDAR+. While these
filings provide access to audit reports
relating to reporting issuers, they do not
constitute a consolidated registry of audit
engagements or audit firms.
3. Architectural Services
The legal framework governing architectural,
landscape architectural, and engineering
services in other jurisdictions, is at an
evolving stage and remains relatively less
restrictive. For the purposes of this section,
the United Kingdom, New Zealand, and
Singapore have been selected due to (a)
their commitments pertaining tothis sub-
sector under GATS, and (b) their significant
export activity in these services and their
participation in the Washington Accord.
Although the Washington Accord primarily
addresses engineering services, it has been
extended to architectural services due to
the overlap in certain covered activities.
(a) Establishment of Legal Entities to
render Architectural Services
There are certain restrictions in the
domestic framework for the establishment
of legal forms of an entity, particularly
limited liability partnerships (LLPs) and
companies, which are prohibited.
United Kingdom: Unlike the Indian
regulatory framework, the UK does not
impose restrictions on the legal form

India’s Services Sector: Insights on Regulatory Regime in Professional Services113
through which architectural services may be
rendered, provided the practice is carried
out under the control, supervision, and
management of a registered person who
does not act in a similar capacity for any
other body corporate, firm, or partnership
(The Architects Act, 1997, sec. 20(3)).
New Zealand: New Zealand's regulatory
framework focuses primarily on the
registration of individual architects rather
than the organizational structure of
architectural practices. Consequently, there
are no specific statutory restrictions on any
legal forms of establishment.
Singapore: The legal framework in Singapore
permits architectural services to be
provided through a variety of organizational
forms, including corporations, partnerships,
and LLPs. Thus, the legislative framework
provides considerable flexibility regarding
establishment structures (The Architects
Act, 1991, sec. 2).
(b) Licensing/Registration Framework
United Kingdom: In the UK, the legal
framework does not provide for any
licensing requirements but provides for
a registration-based mechanism wherein
the individuals must be registered with
the Architects Registration Board (ARB)
inorder to legally use the title “Architect”
(The Architects Act, 1997, sec. 20). Further,
the UK legislation does not mandate any
dual registration, such as regional or local
registration, to practice as an architect.
New Zealand: New Zealand similarly relies
on mandatory registration rather than
licensing. Architects must be registered
with the New Zealand Registered
Architects Board (NZRAB) to use the
title “Registered Architect” (Registered
Architects Act, 2005, sec. 7). Further, there
are no requirements for dual registration or
licensing.
Singapore: Singapore adopts a hybrid
framework with licensing requirements for
specific business entities, such as limited
corporations, unlimited corporations,
partnerships, and limited liability
partnerships engaged in architectural
practice (The Architects Act, 1991, sec.
20). Individual architects are required to
register with the Board of Architects (BOA),
while certain business entities engaged
in architectural practice must obtain
licenses under the Architects Act 1991 (The
Architects Act, 1991, sec. 15). There is no
dual licensing or registration requirement
under the legislation.
(c) Mutual Recognition Agreements or
Reciprocity Agreements
United Kingdom: The Architects Act
1997 expressly authorises the Architects
Registration Board to enter into recognition
agreements with foreign regulatory
authorities with respect to architects (The
Architects Act, 1997, sec. 1AA). Before
entering into such arrangements, the
ARB considers factors such as reciprocity,
equivalence of education and training
outcomes, confidence in regulatory
oversight mechanisms, and the adequacy
of quality assurance systems.
New Zealand: Although New Zealand's
legislation does not expressly contain
provisions authorising mutual recognition
agreements, the NZRAB has entered into
recognition arrangements with several
jurisdictions, including Australia and the
United Kingdom.
Singapore: Singapore's Architects Act 1991
empowers the Board of Architects to enter
into mutual recognition arrangements
concerning qualifications and professional
standards (The Architects Act 1991, sec.
6A(2)). In the context of such arrangements,
an architect must be recognized under

India’s Services Sector: Insights on Regulatory Regime in Professional Services 114
Section 15A, which provides for practical
experience and oral or written examinations.
Such recognition may not exceed one year
and may be renewed upon payment of the
prescribed fee.
4. Engineering Services
(a) Legal and regulatory framework for
engineers
United Kingdom: The engineering
profession in the United Kingdom is not
governed by a comprehensive statutory
framework. Instead, there exists an
Engineering Council, which operate
under a Royal Charter and is governed
by a Board of Trustees and functions as a
regulatory body for engineering services.
The Engineering Council regulates the
competence and ethical requirements
through instruments such as the UK
Standard for Professional Engineering
Competence and Commitment (UK-SPEC).
They also set requirements for recognition
programmes that meet necessary learning
outcomes for professional practice. It also
maintains national registers and awards
professional titles to engineers who satisfy
prescribed standards.
New Zealand: Engineering services in
New Zealand are regulated through the
Chartered Professional Engineers Act, 2002.
This legislation establishes a framework for
recognising competent engineers through
public register and quality mark, using
the protected title ‘Chartered Professional
Engineer. The Act, along with associated
Rules, provides for minimum quality
standards, like educational and professional
competency, complex engineering skills,
and ethical conduct, among others.
Singapore: Singapore regulates engineering
services under the Professional Engineers
Act, 1991, through a Professional Engineers
Board. It provides for the qualification and
registration requirements of professional
engineers. The associated rules and bylaws
include Professional Engineers Board Rules,
Professional Engineers Rules, Professional
Engineers (Qualification for Registration as
Professional Engineers) (Exemption) Order
2016 (new), Professional Engineers (Code
of Professional Conduct and Ethics) Rules,
and Professional Engineers (Approved
Qualifications) Notification 2009.
(b) Licensing mechanism for engineers
United Kingdom: The UK does not impose
any mandatory licensing or registration
requirement for engineers, generally.
However, the Engineering Council
administers a professional registration for
usage of the following titles: Chartered
Engineer (CEng), Incorporated Engineer
(IEng), Engineering Technician (EngTech)
and Information and Communications
Technology Technician (ICTTech).
Even though it is not mandatory to be
professionally registered, registration is a
standard that reflects the competence of
the engineer.
New Zealand: Similarly, in New Zealand, it
was observed that there is a Registration
Authority that regulates Chartered
Professional Engineers. It is responsible for
assessment of applications, maintenance
of the national register, and compliance
concerns (Chartered Professional
Engineers of New Zealand Act, 2002, sec.
39). The authority does not establish any
licensing or registration requirements
for working as an engineer; however,
it does require registration to use the
title "chartered professional engineer"
(Chartered Professional Engineers of New
Zealand Act, 2002, sec. 7).
Singapore: For Singapore, there exists a
Professional Engineers Board for regulating

India’s Services Sector: Insights on Regulatory Regime in Professional Services115
the qualifications and conduct of those
offering engineering services, including
corporations, partnerships, limited liability
partnerships, and limited partnerships
(Professional Engineers Act 1991, sec.
4). The Professional Engineers Act, 1991,
lays down a registration requirement
for engineers to register and a licensing
requirement only for limited corporations,
unlimited corporations, partnerships, and
limited liability partnerships.
(c) Overlaps between architectural and
engineering services
The legal framework of the UK and New
Zealand do not expressly address the overlap
between architectural and engineering
services. In contrast, Singapore’s legislation
explicitly recognizes the relationship
between the two professions. Both the
Architects Act, 1991 and the Professional
Engineers Act, 1991 identify architects
and engineers as “allied professionals”
(section 2 of each Act) and delineate their
respective scopes of practice. Importantly,
these laws permit allied professionals to
perform services within their respective
professional domains notwithstanding
certain functional overlaps, provided such
overlaps are not a substantial part of the
services offered by the other profession.
5. Healthcare services and Allied
Healthcare services
To examine comparative approaches to
the regulation of Healthcare and Allied
Healthcare professional, this section
considers the frameworks adopted in the
United Kingdom, the United States and
Thailand. These jurisdictions have been
selected due to their robust, integrated
regulatory systems, strong governance
infrastructure for healthcare workforce
and differing approaches to professional
mobility. Notably, only the United Kingdom
have committed to this sector under GATS;
the United States and Thailand have not
undertaken any specific commitments.
(a) Barriers to Interstate Mobility of
Health Professionals
Professional mobility enables health
professionals to provide services across
different regions within the country without
facing duplicative licensing requirements.
United Kingdom: The United Kingdom
does not impose separate licensing
requirements for intra-country mobility
of licensed medical professionals across
England, Wales, Scotland or Northern
Ireland. Once registered with the relevant
national regulator, healthcare professionals
may generally practise anywhere across
the country without additional regional
licenses.
United States: The USA follows a state-
based licensing model. However, the
Interstate Medical Licensure Compact
(IMLC) seeks to facilitate physician mobility
by streamlining the licensing process
for physicians who wish to practice in
multiple states. The IMLC is classified under
the IRS Section 115 as a “governmental
instrumentality” which means that it is a
regulating authority part of each state’s
government and has the authority to
collect fees and issue rules. (Information
for states, IMLC)
IMLC currently includes a substantial
number of states and enables eligible
physicians to apply through a centralised
process for licenses in multiple jurisdictions.
The licence(s) would be issued by the
relevant state authorities but since the
process runs through the Compact,
it significantly reduces administrative
burdens and processing time.

India’s Services Sector: Insights on Regulatory Regime in Professional Services 116
Thailand: Thailand operates a nationally
administered licensing framework through
the Medical Council of Thailand. Although,
the country is divided into 13 health
regions for administrative purposes, there
are no regional licensing authorities.
Consequently, a medical practitioner
licensed by the Medical Council of Thailand
may practise throughput Thailand without
additional regional approvals.

India’s Services Sector: Insights on Regulatory Regime in Professional Services117
S. NO. Organisation
1. Animal Welfare Board of India
2. Army Welfare Education Society
3. BMR Legal
4. Centre for WTO Studies
5. Construction Industry Development Council
6. Council of Architecture
7. Cyber Security Association of India
8. Dedicated Freight Corridor Corporation of India Limited, Ministry of Railways
9. Engineering Council of India
10. Federation of Indian Chambers of Commerce and Industry (FICCI)
11. Gandhi & Associates
12. Healthcare Sector Skill Council (HSSC)
13. Indian Association of Physiotherapists
14. Indian National Association of Legal Professionals (INALP)
15. Indian Nursing Council
16. Institute of Engineers (India)
17. Institute of Town Planners, India (ITPI)
18. Lakshmikumaran & Sridharan
19. Larsen & Toubro Limited
20. National Action League for People with Rare Diseases
21. National Health Systems Resource Centre (NHSRC)
22. National Medical Commission
23. NITI Aayog
24. PHD Chamber of Commerce and Industry (PHDCCI)
25. SARAF & Partners
26. Services Export Promotion Council (SEPC)
27. Steel Authority of India Limited
28. Tata Consulting Engineers Limited
29. The Institute of Chartered Accountants of India (ICAI)
30. The Institute of Company Secretaries of India (ICSI)
31. Ujala Cygnus Hospitals
Annexure II
List of Stakeholders who Participated