# ICAI "Holding-Out" Audit
Effective from 9 May 2026. Version 1.1.0.
This memorandum records the compliance posture of ElevateFinance Private Limited ("**ElevateFinance**" or the "**Supplier**") against Section 24A of the Chartered Accountants Act 1949 (the "**CA Act**"). It is read together with the Disclaimer, the Master Services Agreement (the "**MSA**"), the Acceptable Use Policy (the "**AUP**"), and the Terms of Service.
## Defined terms
In this memorandum:
- "**Platform**" or "**Service**" means the software-as-a-service
product operated by ElevateFinance.
- "**ICAI**" means the Institute of Chartered Accountants of India
established under the CA Act.
- "**Code**" means the ICAI Code of Ethics (revised April 2026) and
any successor instrument.
- "**Customer**" means a Chartered Accountant firm or other entity
bound by the MSA.
- "**End-User**" means a natural person whom the Customer authorises
to use the Platform under the Customer's tenant.
## 1. The statutory rule
**Plain-language summary.** Only people who hold a Certificate of Practice from ICAI may call themselves a Chartered Accountant or use language that suggests they are one. The penalty for getting this wrong is fine and possibly imprisonment.
1.1 Section 24A of the CA Act prohibits any person from using a
name or designation that suggests the person is a Chartered
Accountant unless that person holds a Certificate of Practice from
the ICAI.
1.2 The penalty is a fine, and on subsequent offence may include
imprisonment, in each case as set out in the CA Act and any rule
made thereunder.
1.3 ElevateFinance is not a Chartered Accountant firm. The founders are not practising Chartered Accountants. Therefore no User-facing copy may suggest that the Platform, ElevateFinance, or any staff member performs the work that the CA Act reserves for a Chartered Accountant in practice.
## 2. The discipline: approved verbs
**Plain-language summary.** What the product says matters. The verbs below describe what software does. The verbs in the next section describe what only a Chartered Accountant can do, and are therefore off-limits to ElevateFinance copy.
The following formulations are permitted on every Platform surface, every marketing surface, and every support channel:
(a) "computes", "calculates", "runs the math", "applies Section X";
(b) "generates", "produces", "exports";
(c) "traces every number to", "cites", "shows the source";
(d) "prepares a draft for the Chartered Accountant to review";
(e) "helps the User self-file";
(f) "verifies integrity", "verifies the receipt".
## 3. The discipline: forbidden verbs
**Plain-language summary.** These formulations imply that ElevateFinance is doing the work of a Chartered Accountant. They are banned without exception.
The following formulations are not permitted on any Platform surface, any marketing surface, or any support channel:
(a) "advises", "advice";
(b) "recommends", "recommendation";
(c) "we file", "files on the User's behalf";
(d) "our Chartered Accountants", "our panel CAs", except where the CA Review feature is operating under a duly executed empanelment and the empanelment is current;
(e) "CA-certified", "certified by our CAs";
(f) any formulation that compares ElevateFinance's services to the services of a named Chartered Accountant or named firm; and
(g) any formulation that misuses a professional designation
(including describing a non-Chartered-Accountant as a "Chartered
Accountant").
## 4. Tenant-authored copy
**Plain-language summary.** Where a Customer is a Chartered Accountant firm with a Certificate of Practice, the Customer's tenant subdomain may carry the firm's brand and copy, but only within the limits the Code allows. The Platform warns the Customer where the tenant copy is likely to fall foul of the Code.
4.1 The Platform allows the Customer to display tenant-authored copy on the Customer's tenant subdomain (firm name, brand, services list, contact details).
4.2 Tenant-authored copy must comply with the Code, including the
revised Code in force from April 2026. Specifically, tenant copy
shall not include:
(a) any false or misleading claim about the firm, its members, or
the services offered;
(b) any comparative claim against another Chartered Accountant,
firm, or platform;
(c) any fee advertisement that has not been pre-approved under the Code's pre-approval mechanism, where applicable;
(d) any claim of speciality or expertise in any specific tax matter that the relevant ICAI bye-laws restrict;
(e) any reference to clients by name without the client's written
consent; or
(f) any misuse of professional designation.
4.3 The Platform warns the Customer on a best-effort basis where tenant-authored copy is likely to fall foul of clause 4.2. The Customer remains solely responsible for Code compliance.
4.4 ElevateFinance may take down tenant-authored copy under clause 3.4 of the AUP and clause 12 of the MSA on receipt of (a) a credible complaint from the ICAI, (b) a court order, or (c) ElevateFinance's reasonable opinion that the copy materially breaches the Code.
## 5. Audit cadence
**Plain-language summary.** The discipline above is re-checked on every release that touches a User-facing surface. Until the surface- copy lint is fully automated, the audit is run manually.
5.1 The discipline at clauses 2 and 3 is re-checked on every release that touches a User-facing surface or that introduces new marketing or support copy.
5.2 The audit is recorded in ElevateFinance's internal compliance register and is producible to counsel and to the ICAI on request.
## 6. Re-audit trigger
**Plain-language summary.** Reopen this file the moment the product or the regulator changes in any material way.
This memorandum is re-opened the moment any of the following
becomes true:
(a) ElevateFinance launches a feature where a Chartered Accountant employed or empanelled by ElevateFinance authors content that appears to a User as ElevateFinance's own opinion;
(b) the ICAI issues a notification, guideline, or order that
materially changes the analysis above;
(c) a court of competent jurisdiction issues a judgment that bears
on Section 24A of the CA Act in a manner relevant to the Platform;
or
(d) the Customer empanelment model changes (for example, a move from empanelment to direct engagement).
## 7. Cross-references
This memorandum is read together with:
- Disclaimer
- Master Services Agreement
- Acceptable Use Policy
- Terms of Service
- SEBI (Investment Advisers) Regulations 2013 -- Safe-Harbour Mapping
- Privacy Policy
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This memorandum is an internal compliance record. It is published in the `legal/` folder for transparency and for counsel review. It does not create any right enforceable by a third party.