Across Asia’s financial centers, the relationship between a local law firm and an international firm carries a statutory license and a defined regulatory classification. Singapore’s Legal Services Regulatory Authority (LSRA) regulates five distinct collaboration and foreign-entry structures for international practices. In India, equivalent cross-border arrangements provoke Bar Council show-cause notices.
That regulatory divergence explains a market pattern that sector feedback routinely misattributes to client fee sensitivity: why the India corridor is disintermediating faster than any other major market in Asia.
In an August 2025 press release, modified in October 2025, the Bar Council of India (BCI) warned against unregistered combinations between domestic and foreign law firms. The BCI targeted arrangements structured as Swiss Vereins, strategic alliances, referral models, or joint branding that present themselves as unified global legal platforms, citing launch announcements, network marketing, and co-branded websites as evidence of an illegal proxy practice.
Read that regulatory stance against the prevailing market design next door.
The Asian Licensing Baseline and Institutional Memory
Singapore does not merely tolerate formal alliances; it actively regulates them through defined statutory categories under the Legal Profession Act:
- Joint Law Venture (JLV): A joint entity formed by a Singapore law practice and a foreign practice, permitting the foreign constituent to practice in or from Singapore through the venture.
- Formal Law Alliance (FLA): An arrangement allowing independent local and foreign practices to share premises, resources, and client information, and to co-brand and bill for permitted matters.
- Qualifying Foreign Law Practice (QFLP): Grants direct permission to practice Singapore law in permitted commercial areas. (These licenses are awarded periodically via competitive selection rounds; the scheme is currently closed to new applications).
- Foreign Law Practice (FLP): Permits foreign law advice, with Singapore law practice restricted strictly to international commercial arbitration and Singapore International Commercial Court (SICC) proceedings.
- Representative Office / Group Practice: Liaison and collaborative arrangements operating within defined statutory boundaries.
This design recurs across Southeast Asia. From Jakarta to Ho Chi Minh City, formal tie-ups are standard operational procedure:
- Indonesia: Hiswara Bunjamin & Tandjung operates in association with Herbert Smith Freehills; Ginting & Reksodiputro with A&O Shearman; Assegaf Hamzah & Partners holds a strategic alliance with Rajah & Tann.
- Vietnam: Allens, in alliance with Linklaters, was among the first licensed foreign practices; Rajah & Tann LCT Lawyers was formed in 2014 following an alliance between LCT Lawyers and Rajah & Tann.
- Philippines: Tayag Ngochua & Chu allied with Mori Hamada & Matsumoto; MVGS joined the Drew Network Asia.
Across this regional landscape, major independent Indian firms remain conspicuously absent from exclusive international alliances, formal associations, or branded network memberships.
This separation is the product of a thirty-year regulatory memory. When foreign firms first established liaison offices in India in the mid-1990s, the Bombay High Court’s 1995 Lawyers Collective ruling brought that expansion to an abrupt halt. What replaced it was two decades of “fly-in, fly-out” advisory. There were international partners entering on short-term business visas to advise on foreign-law components, while cross-border deal flow was sustained through informal, non-exclusive “best friends” relationships managed between independent senior partners.
The BCI’s Philosophy: Why Swiss Vereins Triggered Regulatory Action
When Dentons combined with Link Legal and CMS partnered with IndusLaw, global law firm branding appeared directly on domestic Indian practice platforms for the first time in decades. The regulatory reaction was immediate: both combinations were named in the BCI’s August 2025 release and received show-cause notices requiring written explanations and documentation of their structure, operations, governance, and public disclosures.
On 21 August 2025, in Atul Sharma v. Bar Council of India, a Delhi High Court bench (Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela) directed the BCI not to decide the show-cause notice issued against Dentons Link Legal, and asked the regulator to revisit its press release as inappropriate while the notice remained pending. The firm’s challenge questions the BCI’s statutory authority under the Advocates Act, 1961, and asserts that the domestic practice remains wholly Indian-owned and controlled.
While the litigation is pending, the BCI’s underlying philosophy is consistent with long-standing policy. It rests on the Supreme Court’s ruling in Bar Council of India v. A.K. Balaji (2018), which strictly prohibited foreign firms from practicing non-litigious Indian law while permitting limited, temporary fly-in advice on foreign law and participation in international arbitrations.
The BCI operates on a straightforward regulatory premise: a foreign firm cannot achieve indirectly (through a Swiss Verein or proxy branding) what it is barred from doing directly. A regulator that prohibits foreign entities from practicing domestic law, yet permits domestic firms to operate under a global brand, concedes the restriction in substance while maintaining it in form.
The regulatory comparison drawn here relies on Singapore’s published licensing framework and the BCI’s public notices. The precise statutory permissions attaching to an association in Indonesia or Vietnam differ materially from Singapore’s structured categories and from each other.
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The Commercial Consequence: Frictionless Disintermediation
The commercial effect of this structural divergence works in both directions.
Where a licensed structure exists (like an FLA in Singapore or an association in Jakarta), the cross-border relationship carries high contractual switching costs. A domestic firm sharing office infrastructure, resources, and co-billing arrangements with a global partner cannot be bypassed on a transaction without contractually unwinding the relationship. Those switching costs give regional referral networks their durability even when commercial alignment weakens.
Where no formal structure exists, the relationship rests entirely on non-exclusive institutional relationships. An Indian firm receiving inbound work from a London or New York firm on an informal basis can be bypassed by a corporate client making a single direct call. There is no FLA to terminate, no Verein membership to unwind, and no joint branding to untangle.
This reframes a market shift usually explained by cost. Global sponsors and corporates instructing Indian firms directly are indeed responding to fee pressure and sophisticated local execution capability. However, the reason the Indian corridor is disintermediating faster than its Southeast Asian counterparts is structural: India is the only major Asian market where the local-international relationship was never permitted to acquire a contractual, high-switching-cost form.
An informal referral relationship is an exposed asset in professional services. It generates revenue, appears on no balance sheet, is owned by individual partners rather than institutions, and can dissolve without a formal trigger. Across most of Asia, firms have converted those flows into contractual structures. In India they have not.
Strategic Adjustments for Practice Leaders
For international law firms, this means the India corridor cannot be secured using the templates that succeeded in Jakarta, Ho Chi Minh City, or Kuala Lumpur. There is no exclusive association to enter and no local firm whose branding can be fully integrated into the global platform. The only available instruments are those that function without structural lock-in: providing genuine foreign-law expertise the Indian firm cannot supply, holding a unique forum position, or owning a highly specialised cross-border problem.
For top-tier Indian firms, independence remains a strategic advantage. The absence of formal tie-ups is precisely why they can capture direct buy-side mandates without network conflicts. However, it requires them to actively manage bespoke, non-exclusive outbound counsel panels for domestic clients expanding internationally, rather than relying on automated network routing.
For specialist firms, this gap is actively filled without formal alliances. India-related cross-border instructions move directly to jurisdiction-specific specialists when a problem exits India and lands in a specific forum. Elias Neocleous on Cyprus matters, Bowmans on African jurisdictions, Gianni & Origoni on Italian matters, or Mori Hamada & Matsumoto and Nishimura & Asahi on Japanese deals, are examples. None of these relationships require a formal alliance or shared logo. They function precisely because they are built on problem ownership rather than platform membership.
Also, formal structures are not costless. Alliance and association arrangements create cross-network conflicts, constrain which local clients a practice can represent, and have unwound acrimoniously in several regional markets. A firm operating without a formal alliance retains strategic independence and conflict freedom that a locked-in network surrenders.
Managing the Structural Reality
A global firm building a position in Singapore evaluates defined, statutory collaboration structures from FLAs and JLVs to foreign law practice licenses, and selects the framework matching its commercial commitment. A global firm building a position in India operates without those statutory templates.
Firms attempting to apply an Asian alliance template to the Indian market are attempting to formalise relationships that the regulator fundamentally rejects. The firms succeeding in the corridor have recognised this reality. They are building the only asset that holds in the absence of a contract: specialised cross-border execution that neither the domestic firm nor the global client can replicate internally.
The Atul Sharma proceedings remain live before the Delhi High Court. The BCI’s authority to enforce its registration framework remains contested, and the Draft Advocates (Amendment) Bill circulated in mid-2026 proposes placing the foreign registration framework directly into the Advocates Act. Any of these developments could alter the baseline rapidly.
Lawfinity Solutions advises international law firms on cross-border legal market positioning. If the India corridor is a live question for your firm, we would be interested in a conversation. Lawfinity works with one firm per jurisdiction. Engagements begin with a single conversation about your firm’s current position and where the corridor question is live for you. Write to Prachi Shrivastava
