When the Standard Becomes the Shield: SA 600, Group Audit Failures, and the Case for Convergence with ISA 600 in India

This paper examines whether, and how, the design of India's group auditing standard, SA 600 (2002), shaped the interpretive conditions in which audit deficiencies arose in corporate failures, and evaluates the case for convergence with ISA 600. The paper draws on documentary analysis of fifty NFRA enforcement outputs — audit quality review reports (AQRRs) and disciplinary orders issued between 2019 and 2024 across six public interest entities — supplemented by NFRA meeting minutes, the regulator's 2024 consultation on a revised standard, and thirty-two comment letters. The analysis is situated against the international literature on group audit quality and divided auditor responsibility. NFRA's enforcement record reveals a consistent pattern: principal auditors treated SA 600 (2002)'s division of responsibility clause as a basis for limiting their engagement responsibility for subsidiaries and associates, even where fraud indicators were visible. The dominant failures were of implementation — non-compliance with requirements SA 600 already imposed — rather than of design; yet the standard's design structured the interpretive environment so that non-compliance became predictable and defensible. The Institute of Chartered Accountants of India (ICAI) did not submit a response to NFRA's public consultation, which effectively constitutes an institutional impasse; while most respondents supported revision, practitioners were divided. Although NFRA's enforcement outputs have featured in Indian professional commentary, they have not previously been mobilised as a systematic empirical corpus in the group audit literature, and this paper is among the first to do so. It demonstrates that standard divergence can create interpretive conditions in which non-compliance becomes institutionally defensible. This has implications for jurisdictions weighing whether and how far to converge national group auditing standards with international requirements on auditor responsibility.