CS Professional · December 2025 · Paper 3
CS Professional Compliance Management, Audit and Due Diligence December 2025: paper analysis
Our own analysis of the official paper, as of 12 October 2026. The questions and answers belong to ICSI; read them on ICSI's website.
Chapter-wise marks
Where the marks were in this paper (out of 100; internal-choice alternatives not double counted).
What each question tested
In our words, by question number. Open the official paper for the full question.
| Q | Marks | Tests | Chapter |
|---|---|---|---|
| 1(a)(i) | 1 | Maximum term for appointing an individual peer-reviewed secretarial auditor under the amended LODR Regulation 24A | Secretarial Audit |
| 1(a)(ii) | 1 | Maximum term for a secretarial audit firm under the amended LODR Regulation 24A | Secretarial Audit |
| 1(a)(iii) | 1 | Reappointment limit for an existing secretarial auditor counting prior tenure under the 2024 LODR amendment | Secretarial Audit |
| 1(a)(iv) | 1 | Identifying material unlisted subsidiaries by turnover threshold relative to consolidated turnover | Secretarial Audit |
| 1(a)(v) | 1 | Which material unlisted subsidiaries are outside the secretarial audit requirement of Regulation 24A, including foreign incorporation | Secretarial Audit |
| 1(b) | 5 | Corporate compliance framework as support for risk management and its three key components | Compliance Framework |
| 1(c) | 5 | Good documentation practice and its dos and donts for statutory registers and records | Documentation and Maintenance of Records |
| 1(d) | 5 | Consequences of wrong certification of annual return and disciplinary action against a practising company secretary | Signing and Certification |
| 2(a) | 5 | Ethics in business where results are pursued regardless of means | Values, Ethics and Professional Conduct |
| 2(b) | 5 | Appeal to the Securities Appellate Tribunal against penalties under the Securities Contracts (Regulation) Act | Non-Compliances, Penalties and Adjudications |
| 2(c) | 5 | Right of a company secretary to appear before NCLT as a quasi-judicial authority, with reference to a tribunal ruling | Legal Framework Governing Company Secretaries |
| 2(d) | 5 | Compliance audit: identifying the audit type and its objectives | Concepts of Various Audits |
| 2A(i) | 5 | Professional misconduct where a practising company secretary lets an unqualified person practise in her name and share fees | Values, Ethics and Professional Conduct |
| 2A(ii) | 5 | Compounding of offences under the Companies Act and cases where compounding is barred | Non-Compliances, Penalties and Adjudications |
| 2A(iii) | 5 | Director responsibility for preparing annual accounts under applicable standards and the going concern basis | Compliance Framework |
| 2A(iv) | 5 | Pre-certification of e-forms by professionals as a duty requiring application of mind | Signing and Certification |
| 3(a) | 5 | Applicability of secretarial audit to a public company using capital, turnover and borrowing thresholds | Secretarial Audit |
| 3(b) | 5 | Forensic audit to investigate suspected corruption and asset misappropriation: nature and purpose | Concepts of Various Audits |
| 3(c) | 5 | Transactions that require due diligence and advantages of conducting due diligence | Due Diligence |
| 4(a) | 3 | Factors that impair the independence of internal auditors | Internal Audit and Performance Audit |
| 4(b) | 3 | Developing an audit plan with professional scepticism | Audit Process and Documentation |
| 4(c) | 3 | Information systems audit and its areas of examination | Concepts of Various Audits |
| 4(d) | 3 | Cross-referencing of working papers as an audit technique | Audit Process and Documentation |
| 4(e) | 3 | Peer review: focus areas and the financial years whose engagement records are reviewed | Peer Review and Quality Review |
| 5(a) | 5 | Purposes of interviews in an audit and their structured or unstructured use across audit phases | Audit Principles and Techniques |
| 5(b) | 5 | Executive summary of audit findings after the exit meeting and its contents | Forming an Opinion and Reporting |
| 5(c) | 5 | When a change in terms of audit engagement is acceptable and precautions before accepting it | Audit Engagement |
| 6(a) | 5 | Key worker protection provisions under the four Labour Codes | Compliance Framework |
| 6(b) | 5 | Dispute resolution forum and process for disagreements arising from a peer review | Peer Review and Quality Review |
| 6(c) | 5 | Auditor responsibility for and signing of the audit report | Forming an Opinion and Reporting |
| 6A(i) | 5 | Quality review: general deficiencies, evaluation of findings and indicators of material deficiency | Peer Review and Quality Review |
| 6A(ii) | 5 | Contents of a non-disclosure agreement used in due diligence | Due Diligence |
| 6A(iii) | 5 | Purpose and forms of audit sampling | Audit Principles and Techniques |
What stood out
- Recent amendments are front-loaded: Q1(a) is five one-mark applied questions on the December 2024 LODR amendment introducing Regulation 24A secretarial auditor terms and material subsidiary coverage.
- Secretarial Audit has the most entries (six): the five one-mark parts of Q1(a) plus a 5-mark applicability test on capital, turnover and borrowing thresholds in Q3(a), all compulsory and fact-based.
- Part II is largely audit theory: Q4 alone has five 3-mark parts spanning auditor independence, audit planning, IS audit, working paper cross-referencing and peer review.
- Peer review and quality review recur across Q4(e), Q6(b) and Q6A(i), making it a reliable high-yield area whichever option is chosen.
- Professional conduct and penalties form a steady block: wrong certification, misconduct by allowing others to practise in ones name, compounding and SAT appeals.
Practise the chapters that carried the marks
Compliance Framework, Concepts of Various Audits, Peer Review and Quality Review: study guides and practice questions in the CS Professional format.