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Your guide to maintaining your firm's record

It is important to maintain an accurate ICAEW firm record. Use this guide to find out what to consider when changing the structure of your firm.

Why you need to maintain your firm’s record

You must notify us of any changes to the structure of your firm within 10 business days. Please do not use the annual return for this purpose as you will be in breach of the Practice Assurance Regulations.

Your firm’s record on our database is used to populate other records that the public and the profession can view. If your firm's record is inaccurate or out of date, it may constitute a misdescription of your firm and lead to more serious issues such as regulatory or disciplinary action.

If your firm is registered for audit, accredited for probate or licensed for DPB (Investment Business) activities, you will be in breach of the Audit Regulations and Guidance, Probate Regulations and the DPB (Investment Business) Handbook.

We record the following information on our database:

  • current name of firm;
  • any trading names used by the firm (which is shown as an additional branch office);
  • addresses of all offices in the firm;
  • names of all principals in the firm (ie, partners, directors or members);
  • names of any insolvency licence holders within the firm;
  • status held by individuals in the firm ie, audit compliance principal, DPB contact principal, probate contact principal, head of legal practice, head of finance and administration and Practice Assurance principal;
  • the registrations held by the firm;
  • any entities connected to the firm;
  • details of the firm’s professional indemnity insurance (PII);
  • for accredited probate firms – names of all authorised individuals and non-authorised owners and addresses of offices which undertake probate work;
  • for audit registered firms – names of all responsible individuals (RIs); and
  • for audit registered or probate accredited firms – the shareholder and voting rights information.

The details listed above must be accurate and up to date to ensure the following display current information:

When we issue pro-forma invoices to regulated firms in November (for the following fee-year), they are based on the structure of the firm shown on our database at that time. If you haven't notified us about any principal retirements or ceased offices etc, the amount you are charged may be incorrect and you may incur higher costs.

In this section

  1. How to notify ICAEW about changes
  2. What information is available to the public and other regulators
  3. Audit considerations
  4. DPB (Investment Business) considerations
  5. ICAEW member firm considerations – is your firm an ICAEW member firm?
  6. Other matters to consider

How to notify ICAEW about changes

Firms working in the specialist areas of audit, ATOL reporting, DPB (Investment Business) and probate

Please inform our regulatory support team of any changes to your firm structure within 10 business days.

  • For changes to the record of an audit registered firm – the audit compliance principal must request changes.
  • For changes to the record of an DPB (Investment Business) licensed firm – the DPB contact principal must request changes.
  • For changes to the record of a probate accredited/licensed firm – the probate contact partner or head of legal practice must request changes.

There are two useful forms for this purpose:

If you require a printed copy of the form, please contact us and we can send you a copy in the post.

Regulatory Support
T +44 (0)1908 546 302
E regulatory.support@icaew.com

Firms not working in the specialist areas of audit, ATOL reporting, DPB (Investment Business) and probate

Please inform our members records team about any changes to your firm structure in writing, by post or email.

Members Records
ICAEW
Metropolitan House
321 Avebury Boulevard
Milton Keynes
MK9 2FZ UK
T +44 (0)1908 248 054
E records@icaew.com

Information available to the public and other regulators

Find a Chartered Accountant

The directory of firms is published at findacharteredaccountant.com. It is updated regularly using the information you provide us with.

Register of statutory auditors

The register of statutory auditors is administered by ICAS. We send data updates to ICAS on a weekly basis. This information is also sent to the Companies Registration Office (CRO) in Ireland. These registers are a statutory requirement and it’s essential they display current information about firms.

The registers show the name of the firm, its principals and owners and any trading names used to sign audit reports. The registers also show the first name and surname of every responsible individual – they must use these two names when they sign audit reports. Their signature can be their usual one, but they must print their first name and surname below the signature.

Some individuals do not use their given first name. They may use a middle name or even a shortened name; for example, Mike instead of Michael. The register can show a preferred name if you request this. Please email regulatory.support@icaew.com to update the information that appears on the register of statutory auditors.

The FCA's register of DPB (Investment Business) licensed firms

The FCA’s financial services register publishes details of all firms licensed by ICAEW for investment business activities under a DPB (Investment Business) licence, including the firm’s DPB (Investment Business) number. This information is taken from the ICAEW database.

The ICAEW register of probate firms

The ICAEW probate register is displayed at icaew.com/probate. It shows a list of accredited probate firms and their details. This information is taken from the ICAEW database.

Find an insolvency practitioner

A directory of insolvency practitioners is administered and published by the Insolvency Service on their website. The information is taken from the ICAEW database. Find an insolvency practitioner provides details of which office an insolvency practitioner is based, along with full contact details. Please note: Any changes received by the Insolvency Service will not be amended on the ICAEW database.

Audit considerations

Voting rights

Regulatory issues can arise where voting rights are held by corporate principals or by corporate owners of the audit firm. The Audit Regulations and Guidance require a firm’s voting rights to be held by audit-qualified individuals or registered audit firms. We can’t look through a group structure when assessing this requirement and only look at the person/body that holds the direct voting rights, rather than any indirect holdings.

Corporate principal with voting rights

It is likely the corporate principal will need to apply for audit affiliate status. However, if the voting rights held by the corporate principal are to be included when assessing the audit-firm’s eligibility, the corporate principal will need to be audit-registered.

Corporate principals and owners

Some firms add corporate principals to their firm structure in addition to individuals, some have corporate principals only and others have a combination of the two.

Additionally, some firms add corporate owners above the main accountancy practice. If your main practice is audit-registered, you will need to take into account the requirements of the Audit Regulations and Guidance when you add a corporate holding company.

Corporate owner with voting rights

If a firm’s majority voting rights are held by a corporate owner then for these rights to be included when assessing the audit-firm’s eligibility, the corporate owner will need to be audit-registered. For example, if 100% of the audit-firm’s voting rights are held by a corporate holding company, which is itself controlled by audit-qualified individuals, the holding company must be audit-registered even if it has no audit clients.

Audit compliance principal

Some audit-registered firms may have solely corporate bodies as principals, not individuals. This is acceptable as long as the audit compliance principal is a responsible individual employee and is also a member of the firm’s management board. Such firms should consider whether they have enough responsible individuals in the firm to carry out, and be responsible for, the audit work and to sign audit reports.

DPB (Investment Business) considerations

When adding corporate principals to a firm that holds a DPB (Investment Business) licence, the DPB contact principal must be a person. The corporate principals may also need to apply for DPB affiliate status if they are not DPB licenced or registered for audit work.

ICAEW member firm considerations

If the voting rights or shares in an accountancy practice (regulated or unregulated) are held by a corporate body, you need to carefully assess whether it still meets the ICAEW member firm definition set out in the Principal Bye-laws.

Two definitions for eligibility

You must consider the member firm definition which determines if you are supervised by ICAEW for money laundering separately from the definition of which firms can use the description ‘chartered accountants'.

An ICAEW member firm is:

  • a member engaged in a public practice as a sole practitioner; or
  • a partnership engaged in public practice of which more than 50 per cent of the rights to vote on all, or substantially all, matters of substance at meetings of the partnership are held by members; or
  • a limited liability partnership engaged in public practice of which more than 50 per cent of the rights to vote on all, or substantially all, matters of substance of the partnership are held members; or
  • any body corporate (other than a limited liability partnership) engaged in public practice of which:
    • 50 per cent or more of the directors are members; and
    • more than 50 per cent of nominal value of the voting shares is held by members; and
    • more than 50 per cent of the aggregate in nominal value of the voting and non-voting shares are held by members.

 An entity in public practice provides accountancy services to clients in anticipation of a financial or equivalent value reward exceeding £100 per assignment where:

  • a. the proportion of the entity’s reported turnover derived from the provision of accountancy or reserved services regularly exceeds 10%; and
  • b. if the entity is part of a group, the proportion of the group’s reported turnover derived from the provision of accountancy or reserved services regularly exceeds 10%.

More detail on what constitutes accountancy services is provided in the ICAEW Statement on Engaging in Public Practice which replaced the former Council statement.

ICAEW member firms are automatically subject to Practice Assurance and money laundering supervision by ICAEW.

There are some common situations where firms find that they do not qualify as a ‘member firm’ under the Principal Bye-laws, including:

  • a subsidiary of another corporate entity, irrespective of the ownership and activities of its parent; and
  • an entity that provides less than 10% accountancy services (although if an entity provides any level of accountancy services it needs a supervisor for anti-money laundering).

If your firm is not a member firm under the definition in the Principal Bye-laws, we may still be able to supervise you for anti-money laundering under a contractual arrangement. If you think you might need a contract, you will find an application form at icaew.com/amlr

Eligibility to use the description ‘Chartered Accountants’

You also need to ensure your firm is eligible to use the description ‘Chartered Accountants’. The Use of Description Chartered Accountants Regulations set out when a firm may describe itself as ‘Chartered Accountant’ and the procedural rules for principals who are not a chartered accountant who must become a general affiliate. Please note the ‘use of description’ member firm definition is different to the definition in the Principal Bye-laws for an ICAEW member firm.

An accountancy practice (regulated or unregulated) may be part of a corporate group. A group entity (which may be a company or LLP) can only be described as a ‘Chartered Accountant’ in the following circumstances.

  • In the case of a parent entity, it is:
    • controlled by chartered accountants; and
    • over 50% of the income of the group is derived from public practice (a holding company can be dormant).
  • In the case of a subsidiary entity, it is:
    • engaged in public practice;
    • majority owned by a parent company that is controlled by chartered accountants; and
    • part of a group where the parent company can use the description.

In the case of a company, 50% or more of the directors must be chartered accountants. Any directors in a parent or subsidiary company that uses the description, who are not chartered accountants, need to become affiliates.

If your firm is not eligible to use the description 'Chartered Accountants', it can apply for permission to use the description. Please complete and submit the use of the description form.

Other matters to consider

Change of legal entity

When considering a change of legal entity, (for example, sole practitioner to partnership; partnership to limited company; limited company to limited liability partnership), if your firm is registered for audit, licensed for DPB (Investment Business) activities or accredited for probate, you must make new applications for these registrations. Full application details can be found at:

An audit registration, DPB (Investment Business) or probate licence cannot be transferred between legal entities.

New applications will be processed by the Regulatory Support team. From receipt of all necessary information for processing, please allow:

  • at least four weeks for audit, DPB (Investment Business), responsible individual (RI) or affiliate applications; and
  • six to eight weeks for insolvency and probate applications.

The new legal entity can’t carry out regulated work until your application(s) have been approved. As part of the application, we will transfer any fees paid by the original firm for that fee-year. If you only notify us of a change to the legal entity on the annual return, rather than when the change took place, this may lead to regulatory or disciplinary action as the new entity will not be properly regulated.

Reserved legal services

The Legal Services Act 2007 opens up new opportunities for ICAEW Chartered Accountants by:

  • allowing new business structures between lawyers, accountants and other professionals (such as IFAs); and
  • allowing accountants to provide reserved legal services which were previously restricted to lawyers.

Regulatory advice about when should a firm apply for a probate licence is available at icaew.com/probate. Please note if an ICAEW member firm is found to have been operating outside this regulatory framework then this will be treated as a disciplinary offence.

Use of ICAEW's consumer credit arrangements

If your firm is not a member firm, audit registered or DPB (Investment Business) licensed, it may not be able to use ICAEW’s consumer credit arrangements. Any consumer credit activity undertaken has to be incidental to the accountancy services a firm provides. FCA authorised firms can’t use ICAEW’s consumer credit arrangements, even if they meet the other criteria. More information is available at icaew.com/ccl