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Corporate Law & M&A · 2 September 2026

CCI Holds Trustees' Association and Three Debenture Trustees Guilty of Fixing Minimum Fees — But Imposes No Penalty

Source: Originally reported by Business Standard, Moneylife, Bar and Bench and LiveLawBiz on and around 2 September 2026, covering the Competition Commission of India's order against the Trustees' Association of India and three debenture trustees. This article has been independently researched and rewritten in full by S&S Co. Advocates & Solicitors for informational purposes — it is not a reproduction of the original reports. Readers are encouraged to consult the original sources and the underlying order directly.

The Competition Commission of India has held that the Trustees' Association of India (TAI) and three major debenture trustees — IDBI Trusteeship Services, Axis Trustee Services and SBICAP Trustee Company — violated Sections 3(3)(a) and 3(3)(b) of the Competition Act, 2002 by collectively fixing a minimum benchmark fee for debenture trusteeship services during FY 2020-21 and FY 2021-22, after TAI decided in March 2021 that members would not price below a common floor and monitored quotations to enforce it.

The complaint was triggered by Muthoot Finance after its long-standing trustee quoted a sharply higher fee for a proposed NCD issuance, prompting the finance company to investigate and ultimately complain to CCI. The Commission issued a cease-and-desist order but imposed no monetary penalty, noting the trustees had abandoned the benchmark-alignment practice once the investigation began — while explicitly warning that any recurrence would be treated as aggravated recidivism.

The ruling confirms that professional and intermediary trade associations in India's debt-capital-markets ecosystem can be held liable for price-fixing under the Competition Act even absent a formal, written cartel agreement, and signals to issuers and trustees alike that association-driven fee benchmarking carries real antitrust exposure notwithstanding the no-penalty outcome here.

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