Registered auditor signing requirements

This helpsheet has been issued by ICAEW’s Technical Advisory Service to help ICAEW members to identify the more common reports prepared by accountants which require a signature by a registered auditor.

Members may also wish to refer to the following related guidance:

• TECH 10/12 AAF Reporting to third parties

Accountants in practice are often asked to provide a wide variety of reports for their clients. These may be required by legislation or regulation, an organisation’s constitution or funding providers.

This helpsheet gives members in practice examples of some common reports they may be asked to provide and highlights whether such reports are required to be prepared by a registered auditor. Please note this is not an exhaustive list of reports.

Members are advised to carefully check the provisions governing the organisation they are reporting on and the report that they are engaged to provide. Furthermore, members need to ensure that they have the necessary skills and expertise to be able to report appropriately and that they are sufficiently independent to be undertaking the work.

Section 1210 of the Companies Act 2006 Act defines the term ‘statutory auditor’, and s1239 requires a register to be kept of all statutory auditors. For the purposes of this helpsheet therefore, the term ‘registered auditor’ encompasses the term ‘statutory auditor’.

References in an organisation’s constitution or regulatory body rules may use alternative terminology. References to ‘qualified auditor’ should usually be construed as meaning ‘registered auditor’ unless the context requires otherwise.

Association of British Travel Agents (ABTA)

ABTA requires its members to submit their accounts within six months of the year end and to follow normal requirements with regard to audit (i.e. companies will need to adhere to the audit requirements of the Companies Act 2006), although ABTA does have the right to require a member’s accounts to be audited.

Where the accounts are audited, the auditor must be a registered auditor. Where the accounts are not audited, the reporting accountant does not need to be a registered auditor but will nevertheless need to be suitably qualified – i.e. a practising member of an appropriate professional body (such as ICAEW).

Air Travel Organiser's Licence (ATOL) and the Civil Aviation Authority (CAA)

ATOL Reporting Accountants (ARAs) must be licenced but do not necessarily need to be registered auditors.

Further guidance is available in the technical release ATOL Reporting Accountants – Reporting to the Civil Aviation Authority (Tech 02/20 AAF).

Audit Bureau of Circulations (ABC)

The ABC Byelaws require that if the ABC doesn’t perform the circulation audit then it must be done by an auditor that has been approved by ABC and who is a registered auditor.

Further guidance is available in the technical release AAF 01/11 Reporting to the Audit Bureau of Circulations Limited (ABC).

Charities

Where an audit is required under the applicable charities legislation (or the charity opts to have an audit), it will need to be conducted by a registered auditor.

Guidance on the external scrutiny requirements for charities can be found in the following helpsheets:

• Charities – financial reporting and scrutiny (England and Wales)
• Charities – financial reporting and scrutiny (Scotland)
• Charities – financial reporting and scrutiny (Northern Ireland)

Charity auditors should also refer to Practice Note 11 (Revised) The audit of charities in the United Kingdom.

Clubs, associations and societies

Specific guidance for clubs, associations and societies registered under the Co-operative and Community Benefit Societies Act 2014 (previously the Industrial and Provident Societies Acts) or the Friendly Societies Acts 1974 or 1992 is contained within the helpsheet Audit of clubs, associations and societies. Such organisations may require an audit or an accountant’s report signed by a registered auditor.

Companies – special reports

In specific circumstances, the Companies Act 2006 requires special reports to be prepared on revised accounts or requires various reports relating to certain distributions, redemption or purchase of own shares and share allotment by a public company other than for cash. These reports are required to be signed by a registered auditor.

Further details can be found in Bulletin 2008/5 Auditor’s Reports on Revised Accounts and Reports, in the United Kingdom and Bulletin 2008/9 Miscellaneous Reports by Auditors under the United Kingdom Companies Act 2006.

Employment agencies

Employment agencies holding client money at any time during an accounting period are required by paragraph 10 of Schedule 2 to The Conduct of Employment Agencies and Employment Business Regulations 2003 (SI 2003/3319) to have their client money records inspected and reported upon by an independent reporting accountant. This person does not need to be a registered auditor but must be a member of a professional body.

Financial Conduct Authority (FCA)

Where firms subject to FCA regulation are required to appoint an auditor in accordance with the FCA Handbook, the auditor will usually be required to be a registered auditor, although this does depend on the specific legislative requirement driving the need for an audit.

Where an auditor is reporting on client assets, they should consult the FRC publication Providing Assurance on Client Assets to the Financial Conduct Authority for further guidance.

Grant claims and other public body reports

Grants awarded by the EU, the Department for Business, Energy and Industrial Society (BEIS), other governmental departments or via other sources, such as the National Lottery, often require an independent audit, which generally needs to be carried out by a registered auditor. However, it is important to check the specific requirements of the particular grant scheme with the grant provider.

Further guidance can be found in technical release AAF 01/10 Framework document for accountants’ reports on grant claims, although this does emphasise the separation of the ‘reporting accountant’ and the auditor of the grant recipient’s financial statements.

International Air Transport Association (IATA)

IATA’s requirements are set out in the IATA Travel Agent’s Handbook. Most agents are required to submit accounts audited by a statutory auditor.

Agents which are sole traders, partnerships or UK registered limited companies that meet the conditions for exemption from audit as a small company as defined by the UK Companies Act may submit ‘certified’ accounts. Such ‘certifications’ must be issued by an independent reporting accountant who is either a statutory auditor or a qualified accountant holding a current practising certificate with a recognised accountancy body (such as ICAEW). 

Letting and property management agents

Letting and property management agents in the private rented sector who hold client money are required to belong to a government approved client money protection (CMP) scheme from 1 April 2019. Government approved schemes include Client Money Protect, Money Shield, safeagent (previously NALS) Client Money Protection, Propertymark, RICS and UKALA Client Money Protection.

Whilst some of these schemes conduct their own reviews and compliance monitoring, others including Money Shield and Propertymark usually require accountants to sign client money reports.

• Money Shield
  The Money Shield Scheme Rules require agents under the scheme to submit annually either an accountant’s report or (in limited circumstances) undertake a ‘HealthCheck’ which is carried out by The Lettings Partnership.
  The reporting accountant (according to rule 8.1) must be a practising member of a specified professional body (which includes ICAEW). In the (rare) cases where funds held are subject to the Estate Agents Act 1979 they must also be a registered auditor.
• Propertymark
  The Propertymark brand includes both ARLA Propertymark (previously the Association of Residential Letting Agents) and NAEA Propertymark (previously the National Association of Estate Agents).
  Members of Propertymark are required to adhere to its conduct and membership rules. Subject to a number of exceptions, Propertymark members holding client money are required to obtain an accountant’s report each year. The reporting accountant must (according to rule 1.24) be a member of a relevant professional body (which includes ICAEW). In the (rare) cases where funds held are subject to the Estate Agents Act 1979 they must also be a registered auditor.

Mortgage references

Mortgage references do not usually need to be signed by a registered auditor. Care should be taken when providing such a reference however and the helpsheet References on clients’ financial status should be consulted for further guidance.

Pension schemes

Audits of occupational pension schemes can only be carried out by a registered auditor. Any members auditing pension schemes should consult Practice Note 15 (Revised) The audit of occupational pension schemes in the United Kingdom.

The Pensions Act 1995 requires all occupational pension schemes, unless exempt, to be audited by a registered auditor. The current exemptions from the requirements to appoint professional advisers (including an auditor) are set out in the Occupational Pension Schemes (Scheme Administration) Regulations 1996 (as amended) (SI 1996/1715).

Members working with small self-administered pension schemes (SSAS pension schemes) may wish to view the helpsheet Which accounting standard do I use for SSAS pension schemes?.

Registered social landlords (RSLs) / Housing associations

The Housing and Regeneration Act 2008 requires all RSLs which are registered with the Homes and Communities Agency (HCA) to be audited by a registered auditor, unless they are eligible to apply the audit exemptions available to a company, a charity, a friendly society or a co-operative and community benefit society as appropriate and provided their rules permit them to do so. The HCA nevertheless retains the right to require an RSL’s accounts to be audited.

Where the RSL is not audited, it will require an accountant’s report. For most RSLs this does not need to be signed by a registered auditor. If, however, the RSL is a co-operative and community benefit society or friendly society, the accountants report may need to be signed by a registered auditor. Further guidance for such societies is included in the helpsheet Audit of clubs, associations and societies.

Any members auditing housing associations registered in the UK should consult Practice Note 14 The audit of housing associations in the United Kingdom.

Service charge accounts

There are a number of possible different types of reporting on service charge accounts:

• If the terms of the lease require or are construed as requiring an audit, then the report will need to be an ISA 800 report meaning the auditor will need to have implemented ISQC 1, or ISQM 1 from 15 December 2022. auditor will need to be a registered auditor. If the reporting accountant is not a registered auditor, this fact must be made clear in the details accompanying the auditor’s signature on the audit report.
• An engagement to deliver a report on factual findings will not need to be undertaken by a registered auditor unless the terms of the lease so require.
• A report under section 21 of the Landlords and Tenants Act 1985 is required to be made by a registered auditor.

The detailed guidance on this area can be found in technical release Tech 03/11 Residential Service Charge Accounts.

Solicitors Regulation Authority (SRA) client money rules

Most firms of solicitors holding client money are required by the SRA accounts rules to obtain an accountants’ report. The SRA’s rules require the reporting accountant to be, or work for, a registered auditor.

The ICAEW Library and Information Service is able to provide access to a range of external resources to support members including a selection of sample engagement letters and sample work programmes for a number of the above types of engagement. Members can email library@icaew.com or call +44 (0)20 7920 8620 with their request.

ICAEW members, affiliates, ICAEW students and staff in eligible firms with member firm access can discuss their specific situation with the Technical Advisory Service on +44 (0)1908 248 250 or via webchat.