ICSI practical training and internship requirements

In short

Practical training is the compulsory on-the-job stage of the Company Secretary course: after clearing the Executive Programme, a student must serve a prescribed period of training with a company, a Practising Company Secretary (PCS) or another body approved by ICSI, sandwiched between two institute-run programmes (EDP before, CLDP after). It exists because the Company Secretaries Act, 1980 and the Company Secretaries Regulations, 1982 make training, not just examination success, a condition for admission as an Associate Company Secretary (ACS). The training is where a student actually files MGT-7 and AOC-4, drafts board minutes, runs an AGM and assists in a secretarial audit under section 204 of the Companies Act, 2013. It is examined directly in "CS profession and course" type questions and in viva/interview rounds, and every employer screening a fresher CS asks what the trainee personally handled. ICSI revises the structure by amending the Regulations and issuing training guidelines, so the scheme applicable to a student is the one in force on their registration — the durations below are those of the current (post-2020) structure.

Explained

Why training is mandatory, and the law behind it

• The Company Secretaries Act, 1980 created ICSI and empowers it to prescribe qualifications; the Company Secretaries Regulations, 1982 (amended repeatedly, materially by the amendment Regulations of 2020) carry the training provisions.
• Membership as ACS requires three things together: passing the Professional Programme, completing the prescribed practical training (or holding an exemption), and being of prescribed age and character. Passing the exams alone gives no right to membership.
• Rationale: a Company Secretary is a Key Managerial Personnel under section 203 of the Companies Act, 2013 and signs statutory returns; the role is compliance-certifying, so supervised field experience is treated as a professional entry barrier (the same logic as CA articleship).
• Training is also the practical base for later secretarial audit (s.204), annual return certification (s.92(2)) and pre-certification of e-forms, which only a member can do.
• ICSI treats training as a registered, auditable engagement — not an informal internship. Unregistered work experience, however good, earns no training credit.

The current training structure, stage by stage

1. CSEET (entrance test) → Executive Programme → Professional Programme is the academic spine; training attaches to it after the Executive Programme.
2. Executive Development Programme (EDP) — a classroom/online programme of one month that a student must complete after passing the Executive Programme and before commencing practical training. It covers company law practice, e-filing, drafting, Ind AS basics, soft skills and interview preparation.
3. Practical training — 21 months — commenced only after the EDP, with an ICSI-registered trainer. It may run concurrently with Professional Programme studies, which is why most students start training immediately rather than after passing the Professional Programme.
4. Corporate Leadership Development Programme (CLDP) — the final, residential/classroom programme, taken after passing the Professional Programme and completing training; it ends with a presentation/assessment and is the gateway to applying for ACS. (Under the current guidelines it runs for about a month; students under the earlier structure completed a 15-day MSOP instead.)
5. Earlier structure (for context and for transitional students): 7-day SIP + 8-day EDP + 15 months training + 25-hour PDP + 15-day MSOP. Exam questions written before 2020 still describe this; say which structure you are answering under.
6. Order matters. Training served before the EDP, or before passing the Executive Programme, is normally not counted; so is training with an entity not on ICSI's approved list on the date of commencement.

Where a student may train — eligible trainers

• Companies registered with ICSI as training organisations: typically companies that have a Company Secretary in whole-time employment, or that satisfy ICSI's paid-up capital/turnover and infrastructure norms. ICSI publishes the list of registered companies.
• Company Secretaries in Practice (PCS) holding a Certificate of Practice — the most common route, and the best exposure to secretarial audit, incorporations, LLP work and ROC litigation.
• Specified bodies/other organisations approved by ICSI: banks, financial institutions, insurance companies, stock exchanges, SEBI-registered intermediaries, regulators and government departments, firms of practising CA/CMA/advocates, and ICSI's own offices. Only part of the 21 months may be served in such bodies — the permitted fraction is fixed by ICSI's training guidelines, so confirm the current cap before signing up.
• Intake caps: a PCS may train only a limited number of trainees at a time, graded by the number of years the Certificate of Practice has been held; companies have their own ceilings linked to the number of CS employees. The slabs are set by ICSI guidelines and are revised periodically.
• A student may not train with an entity where the arrangement is nominal (no supervising CS, no real secretarial work) — ICSI can refuse credit on inspection.
• Transfer of training is allowed with the trainer's no-objection and ICSI's approval, within the limited number of transfers permitted; abandoning training without a transfer order forfeits the period served.

Registration, records and compliance during training

• Register the training online on ICSI's training/learning portal: the student applies, the trainer accepts, and ICSI issues a registration — do this at or before commencement, within the window ICSI prescribes. Retrospective registration is generally not allowed.
• The engagement rests on a training agreement/undertaking between student and trainer specifying the period, stipend and work.
• Periodic progress reports (quarterly, in ICSI's format) are filed by the student and countersigned by the trainer; a training completion certificate from the trainer closes the period.
• Maintain a work diary of assignments — forms filed, minutes drafted, audits assisted. ICSI can call for it, and it is the single most useful document in a placement interview.
• Leave is allowed to the extent ICSI prescribes (a fixed entitlement over the training period, plus examination leave); absence beyond the entitlement extends the training by an equal period, pushing back the completion date.
• No parallel full-time employment or regular day college during training; training hours follow the trainer's normal office hours. Breach can lead to the period being disallowed.
• Termination by either side requires intimation to ICSI; the served period may be counted if ICSI permits, which is why unilateral walk-outs are costly.

Stipend and the trainee's position

• ICSI prescribes a minimum monthly stipend, differing by type of trainer (PCS versus company) and sometimes by city class; the amounts are notified by circular and revised from time to time, so quote the current circular rather than a remembered figure. Large corporates and law firms pay well above the floor.
• The stipend is paid by the trainer, not by ICSI, and a trainee is a trainee, not an employee — no appointment letter, no PF/ESI entitlement by virtue of training, and the period is not "work experience" for seniority.
• Trainees owe the trainer and the client confidentiality; ICSI's disciplinary framework and the trainer's professional obligations extend to information a trainee sees (price-sensitive information, SEBI (PIT) Regulations, 2015 implications are real).
• Typical learning deliverables to insist on: incorporation (SPICe+), board and general meeting process end-to-end, annual filings (AOC-4, MGT-7/7A, DIR-3 KYC), charge and allotment filings (CHG-1, PAS-3), minutes and registers, listed-company work (LODR disclosures) and at least one secretarial audit.

Exemptions and relaxations

• ICSI may grant full or partial exemption from practical training on the basis of prior employment experience in a secretarial, legal, finance, accounts or administration role, subject to the prescribed designation and the employer's prescribed size (paid-up capital/turnover) criteria; the student applies in the prescribed form with the fee and documentary proof, before claiming the exemption.
• Members of sister institutes and certain qualifications can get partial credit; the recognised list and the credit allowed are set out in ICSI's training guidelines.
• Exemption is never automatic — the period is deemed served only when ICSI issues the exemption order. Students who assume it and skip registration lose months.
• Exemption from training does not exempt EDP/CLDP, which remain compulsory unless ICSI's order says otherwise.
• Physical-disability and other hardship relaxations are considered case by case on application.

How it compares with the other professional bodies

• ICSI's structure is training after Intermediate-level (Executive) pass, concurrent with the final level — broadly the ICMAI philosophy too, but unlike ICAI's scheme from 1 July 2023 (where the Final exam may be attempted only after the whole 24 months plus a six-month study period), and with a shorter period and heavier institute-run bookends (EDP/CLDP).
• The practical consequence: a CS student who starts training promptly after the Executive result finishes training and the Professional Programme at roughly the same time and can apply for ACS within months of the final result; one who waits for the Professional result adds nearly two years.

Key points

• Practical training - compulsory registered on-the-job stage under the Company Secretaries Regulations, 1982; a condition precedent to ACS membership, not optional polish.
• Current period - 21 months of practical training under the post-2020 structure (15 months under the earlier structure).
• EDP - one-month Executive Development Programme, after the Executive Programme pass and before training begins.
• CLDP - the final institute programme, after both the Professional Programme pass and completion of training; the earlier structure's equivalent was the 15-day MSOP.
• Eligible trainers - ICSI-registered companies, PCS holding a Certificate of Practice, and approved specified bodies; only part of the period may be served in specified bodies.
• Concurrency - training may run alongside Professional Programme studies; this is the single biggest timeline saver.
• Registration first - training counts only from the date ICSI registers it; retrospective credit is generally refused.
• Intake caps - a PCS/company can take only a limited number of trainees at a time, graded by years of CoP or number of CS employees.
• Stipend - minimum prescribed by ICSI circular (varies by trainer type/city, revised periodically) and paid by the trainer, not ICSI.
• Not employment - a trainee is not an employee; no statutory employment benefits arise from training alone.
• Leave - limited entitlement per ICSI guidelines; excess absence extends the completion date day for day.
• Reports - quarterly progress reports plus a trainer's completion certificate; keep a personal work diary.
• Transfer - permitted with NOC and ICSI approval, limited in number; unilateral abandonment risks forfeiting the period.
• Exemption - full or partial, on the basis of prior qualifying experience, only by ICSI order on a formal application.
• No parallel full-time job or regular college during training; office hours follow the trainer.
• Why it matters legally - the trained member later certifies annual returns (s.92(2)) and conducts secretarial audit (s.204) of the Companies Act, 2013.
• Structure follows registration date - always answer, and plan, under the scheme in force for that student's registration.

Examples

Example 1 — Standard timeline (dates arithmetic). A student's Executive Programme (both modules) result is declared 25 February 2027.

• EDP (one month): March 2027.
• Training registered to commence 1 April 2027; 21 months from 1 April 2027 ends on 31 December 2028 (1 April 2027 + 21 months = 1 January 2029, so the last day served is 31 December 2028).
• Professional Programme cleared in the December 2028 session (result February 2029) → CLDP thereafter → ACS application in the first half of 2029.

Total from Executive result to ACS eligibility: about 2 years 3 months.

Example 2 — Cost of waiting. The same student instead waits for the Professional Programme result (February 2029) and starts training on 1 April 2029. 21 months ends 31 December 2030 — two full years later than Example 1, for identical exam performance. Concurrency, not extra study, is what compresses the CS timeline.

Example 3 — Excess leave extends training. Entitled leave is exhausted and the student is absent a further 24 days.

• Scheduled completion: 31 December 2028. Extension = 24 days → revised completion 24 January 2029.
• If the trainee had instead planned exam leave within the entitlement, the date would be unchanged. Any gap must be made good day for day.

Example 4 — Stipend over the training period. A PCS firm pays ₹8,000 per month for the first 9 months and ₹12,000 per month thereafter.

• First 9 months: 9 × ₹8,000 = ₹72,000.
• Remaining 12 months: 12 × ₹12,000 = ₹1,44,000.
• Total over 21 months = ₹2,16,000, i.e. an average of ₹2,16,000 ÷ 21 ≈ ₹10,286 per month. Compare this average, not the opening figure, against the ICSI minimum then in force.

Example 5 — Partial exemption (illustrative). A student with four years' service in the secretarial department of an unlisted public company applies for exemption with the prescribed form, fee and employer certificate. ICSI grants partial exemption of 12 months.

• Residual training = 21 − 12 = 9 months, to be registered and served with an approved trainer.
• EDP and CLDP still apply. Had the student skipped registration assuming full exemption, the 9 months would have been served with no credit.

Where it is used

• Listed companies and large unlisted companies (Infosys, Reliance, HDFC Bank, L&T, Tata group): trainees in the secretarial department handle board/committee papers, LODR disclosures, e-voting and AGM logistics, and insider-trading compliance under SEBI (PIT) Regulations, 2015.
• PCS firms and secretarial consultancies: incorporations and conversions, ROC filings and condonation/compounding petitions, due diligence, search reports for banks, secretarial audit fieldwork — the broadest exposure per month of training.
• Law firms and CA/CMA firms: corporate advisory, FEMA and NCLT work, transaction documentation and compliance review support.
• Banks, NBFCs and SEBI-registered intermediaries: compliance-officer-support roles, RBI returns, KYC/AML processes and policy drafting — a common route into the compliance function.
• Regulators and exchanges (where approved): processing of listing and disclosure filings; useful for later roles in exchange compliance teams.
• Placement outcome: the registered training record, the work diary and the CLDP assessment are what ICSI campus recruiters and corporate secretarial teams screen for when hiring freshers as Assistant Company Secretary or Compliance Executive.

Interview questions

• Q: Is practical training compulsory for ACS membership? A: Yes — the Company Secretaries Act, 1980 and the Regulations, 1982 make completion of the prescribed training (or an ICSI-granted exemption) a condition for admission, in addition to passing the Professional Programme.
• Q: When can a student begin practical training? A: After passing the Executive Programme and completing the one-month EDP; the training is then registered with ICSI and may run concurrently with Professional Programme studies.
• Q: How long is the training under the current structure? A: 21 months of practical training, bookended by the EDP before and the CLDP after; the earlier structure prescribed 15 months with an 8-day EDP and a 15-day MSOP.
• Q: With whom can you train? A: An ICSI-registered company, a Company Secretary in Practice holding a Certificate of Practice, or a specified body approved by ICSI — with only part of the period permitted in specified bodies.
• Q: What happens if you start work without registering the training? A: The period is generally not counted; ICSI credits training from the date of registration, so the months are lost and must be served again.
• Q: Is the trainee an employee of the trainer? A: No — a trainee is a student under supervision, paid a stipend prescribed as a minimum by ICSI; statutory employment benefits do not arise from the training relationship.
• Q: Can you take a full-time job while undergoing training? A: No. Training must occupy the trainer's normal working hours, and parallel full-time employment or a regular day course can cause the period to be disallowed.
• Q: How is excess leave treated? A: Leave beyond the prescribed entitlement extends the training period by an equal number of days, shifting the completion date.
• Q: Can training be transferred from one trainer to another? A: Yes, with the existing trainer's no-objection and ICSI's approval, within the limited number of transfers permitted; abandoning training without approval risks forfeiture.
• Q: How does one claim exemption from training? A: By applying to ICSI in the prescribed form with fee and documentary proof of qualifying experience in a secretarial/legal/finance role with an employer meeting the prescribed criteria; the exemption takes effect only when ICSI passes the order, and EDP/CLDP still apply.
• Q: What is the CLDP and when is it taken? A: The Corporate Leadership Development Programme — the final mandatory institute programme, taken after both passing the Professional Programme and completing practical training, immediately before applying for ACS.
• Q: Which single document best proves what you learnt in training? A: The work diary of assignments — forms filed, minutes and resolutions drafted, meetings and audits assisted — backed by the trainer's completion certificate.

Common mistakes

• Treating any internship as training: only training registered with ICSI, with an approved trainer, from the registered date, earns credit.
• Starting the 21 months before the EDP or before the Executive Programme result, and discovering later that the period does not count.
• Waiting for the Professional Programme result before beginning training, adding roughly two years to qualification for no academic gain.
• Assuming an exemption will be granted and not registering training in the meantime; the exemption exists only once ICSI issues the order.
• Quoting the old 15-month/SIP/MSOP structure in an exam answer without saying which structure is being described, or quoting a remembered stipend figure instead of the current ICSI circular.
• Missing quarterly progress reports or failing to collect the trainer's completion certificate, which stalls the ACS application after everything else is finished.
• Leaving a trainer unilaterally, without a transfer order, and losing the months already served.

Related topics

CS careers: in employment and in practice · ACS membership and certificate of practice · Appointment of Key Managerial Personnel under section 203 · Secretarial audit under section 204 and Form MR-3 · CSEET and the CS course structure · ICSI Code of Conduct and professional ethics