Section 23

Section 23 governs the renewal of a Certifying Authority's licence. Three requirements apply: the renewal application must be in the prescribed form; it must be accompanied by the prescribed fee (capped at Rs 5,000 by the section, considerably lower than the original application fee cap of Rs 25,000 under Section 22); and crucially, it must be filed at least 45 days before the licence expiry date. The 45-day advance filing requirement is operationally significant. A CA licence is the legal foundation for all certificate-issuance activity — if a licence expires without renewal, the CA technically has no authority to issue new certificates and its existing issued certificates' validity could be questioned. The 45-day window allows the Controller to process the renewal without disrupting the CA's operations. If a CA fails to apply in time, it faces the risk of operating in a legal grey zone as its licence lapses. The renewal process is also an opportunity for the Controller to assess continuing compliance — a CA that has accumulated regulatory concerns during its licence period may face conditions attached to the renewed licence or, if concerns are serious, may be denied renewal. Section 23 is brief but important as the maintenance mechanism that prevents licences from being treated as permanent once granted, ensuring periodic regulatory review.