Who needs to have a PA visit?

The PA scheme covers ICAEW member firms, practising certificate holders, and any firms with a PA contract. Anyone meeting these criteria is subject to monitoring by the QAD team and you can expect a PA visit at least every eight years. However, factors such as firm size, complexity, previous visit history, and risk monitoring activities may necessitate more frequent visits.

If your firm has a DPB (Investment Business) licence or probate accreditation we will usually carry out these visits at the same time as the PA visit if possible. However, audit visits will generally be undertaken separately as they are on a different cycle, with a mandatory requirement for a visit at least every six years.

What is the purpose of the visit?

ICAEW’s monitoring supports its objective to maintain standards and strengthen trust in the profession and the primary purpose of a QAD PA visit is to reassure firms that they continue to meet the requirements of the PA Standards, other relevant regulations and the ICAEW Code of Ethics. The visit also covers necessary actions taken following any previous monitoring review, and a review of updated procedures for recent changes in laws and regulations.

Getting ready for a PA visit

Once your firm has received notification about an upcoming PA visit, there are some key steps you can take to prepare. You should read the pre-visit booklet for the type of visit you are expecting and familiarise yourself with the resources available on ICAEW’s website, including guidance, common pitfalls sections, and webinars for new firms (see our useful resources section for relevant links below). If this isn’t your first PA visit, you should reflect on previous visits, reviewing matters that required action from the last visit to ensure that they have been resolved satisfactorily.

You should start making practical steps to prepare for the visit itself, ensuring that individuals responsible for compliance, including the Practice Assurance Compliance Principal and the Money Laundering Reporting Officer, are available for the duration of the visit, noting that their availability is key to ensuring that your reviewer can gather all the relevant answers that they need to be able to complete the process. You should prepare key documentation as outlined in the pre-visit booklet.

What to expect during the visit

Your reviewer will have prepared for your visit as much as possible in advance, including reviewing the results of the previous visit (if applicable), the annual return and the firm’s website.

All visits start with an opening meeting which usually lasts around 90 mins. This opening meeting will be with the PA principal and any other relevant individuals, including the MLRO and DPB or probate compliance principals (if relevant). During this meeting, your reviewer will get a better understanding of your firm, including your firm structure, service lines, clients and financials.

Your reviewer will go on to discuss processes and procedures in key areas including Anti-Money Laundering (AML), Clients’ Money regulations (if you hold clients’ money), Professional Indemnity Insurance, Data protection, any commission or referral fees, engagement letters, and any other areas of focus.

After the opening meeting, your reviewer will examine the documentation that we have requested. The reviewer will also inspect a sample of client files, selected during the visit, to see how you have applied your processes in practice.

What are the possible outcomes of the visit?

At the end of the visit, your reviewer will summarise any findings that require action in a document known as the closing record, and they will go through this with you at the end of the onsite visit.

The closing record has a space against each finding for your responses, and we ask you to send in your written responses within 15 business days of the closing meeting. You are not expected to have fully addressed every matter within 15 days, rather provide a realistic plan and timeline of how you are going to deal with the matter going forward.

The outcome of the PA visit will fall into one of the following categories:

• If no matters require action, or the matters identified do not required follow-up, the visit is closed.
• If more evidence is needed, formal follow-up may be required until satisfactory evidence is received.
• Significant areas of non-compliance are reported to the Practice Assurance Committee, with firms given the opportunity to make representations.

Overall visit outcome statistics are disclosed in ICAEW’s annual practice assurance monitoring report.