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Three-month grace period for Senior Accounting Officer filings

15 September 2020: The automatic extension of Companies House filing deadlines in light of the coronavirus pandemic provides breathing space for SAOs.

The deadline for submission of Senior Accounting Officer (SAO) filings follows the statutory accounts filing deadlines. In response to the coronavirus pandemic, Companies House is automatically extending the accounts filing deadlines by three months where these fall between 27 June 2020 and 5 April 2021 inclusive. Therefore, those businesses that receive a three-month extension from Companies House for filing statutory accounts, will also have an additional three months to submit their SAO filings to HMRC.

For private companies, the deadline for the submission of SAO documents to HMRC, including the certificate, is nine months after the accounting period. Many December year-ends will normally be expecting to file on 30 September 2020. However, if required a three-month extension will automatically apply.

For listed companies the accounts filing deadline is six months after the year end so public companies with March year ends will be in a similar position.

ICAEW’s Tax Faculty recommends that where businesses have an HMRC Customer Compliance Manager they inform them in advance of the original deadline if they are going to take advantage of the extension. This will help maintain a good working relationship with HMRC and ensure that HMRC is kept informed about the business’ compliance status.

The extension might mean that some businesses who have missed the original deadline can still submit their SAO filings on time. The faculty would therefore urge businesses to consider their SAO documentation and any outstanding or upcoming filing deadlines. 

It is also important to note that the individual who is the SAO needs to consider compliance with the regime carefully – in particular meeting the “main duty” requirement which is to “take reasonable steps to establish and maintain appropriate tax accounting arrangements”.

Where a “clean” certificate is filed, the SAO should be able to support this with evidence of appropriate documentation, systems and controls including some form of monitoring on an annual basis.