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New 2025 Audit Regulations: notification requirements and sole practitioner alternates

Author: Professional Standards Department

Published: 02 Apr 2025

2025 changes to Audit Regulations are now confirmed and will take effect on 1st June. The new regulations introduce a requirement for ICAEW-registered audit firms to notify ICAEW when appointed to certain complex or high-risk audits. There is also a new requirement for sole practice auditors to appoint an alternate. Sole practice auditors will have until the end of a six month transition period to appoint an alternate (ie, until 1st December 2025).

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AI disclaimer

This audio file was produced by AI and is based on the regulatory news article above on 2025 Audit Regulations changes. This has been adapted from the original article for audio purposes. All links to downloads can be found in the original article.

These changes follow consultation processes held during 2023 and 2024. The feedback received has been reviewed and where appropriate, incorporated into the final updated regulations which have now been approved by the ICAEW Regulatory Board (IRB).

A tracked changes version of the regulations to show the exact changes is available on request.

Notifying ICAEW about the movement of relevant audits

As part of the new audit requirements, ICAEW-registered audit firms must notify ICAEW when they are appointed to certain audits that are considered complex or high risk. The notification process is intended to provide increased regulator visibility of the movement of certain complex or higher risk audits and the changes are effective from 1 June 2025.

When is notification required?

Notification will be required if a firm is appointed auditor to:

  • a listed entity; or
  • an entity with turnover greater than £750 million, or which is an Other Entity of Public Interest under the FRC Ethical Standard; or
  • entities where the expected first year audit fee for the entity/group/collection of entities under the same beneficial owner or controlling party is more than twice the firm’s existing highest audit fee, subject to a de minimis of £25,000 for the first year audit fee; or
  • an audit where the audit firm has three or fewer responsible individuals and the audited entity (or group or entities under common beneficial ownership or control) has combined turnover greater than £750 million.

Notification will not be required for audits where the firm already has to notify the Financial Reporting Council (FRC) of the appointment (this applies for audits of public interest entities and other audits retained by the FRC).

When and how to notify ICAEW

ICAEW-registered audit firms must notify ICAEW:

  • within 21 business days of being appointed as auditors of the types of entities listed above; or
  • when an existing audit client meets the criteria for the first time.
Audit notification requirements guidance (Regulations 3.15A–D)

Read our full guidance note which has been put together to assist audit registered firms with applying the new regulations.

Waiver option for firms with relevant experience

Firms who wish to apply to the Audit Registration Committee (ARC) for a waiver from the 21-day notification requirement should complete the below form as soon as possible.

The ARC will issue a waiver if it is satisfied that the firm has substantial experience and capability in carrying out the types of audits that are notifiable.

If a waiver is granted, firms must instead submit the required audit notifications annually, via a specified template alongside their next annual return (from 1 June 2025 onwards).

Sole practice auditor alternates

Under the revised Audit Regulations sole practice auditors will be required to appoint an alternate. This will ensure that another practitioner can intervene in circumstances where a sole practitioner is unable to practice, for example as a result of serious illness.

Key points about the alternate

The role of the alternate is to ensure continuity of services and to effect a transition of clients to another auditor. There is no requirement for the alternate to undertake the business of the sole practitioner.

  • The alternate can be an ICAEW, ICAS, CAI, or ACCA member.
  • The alternate does not need to be a responsible individual.
  • The alternate does not need to hold a practising certificate.

Further guidance on the appointment of an alternate will be published shortly.

Need help understanding the new Audit Regulations?

  • If you have questions about any of the new audit requirements – including how to notify ICAEW or appoint an alternate – please contact our Technical Advisory Service on +44 (0)1908 248 250 or via live chat with one of our experts. Open 9–4 Monday–Friday except Wednesday 10–4. Closed 9–2 first Wednesday of each month (UK time).

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