ATOL Reporting Accountants Scheme

The ATOL Reporting Accountants Scheme, which forms part of the Civil Aviation Authority's ("the CAA's") review of ATOL regulation, was launched on 1 April 2016.  From that date, only registered and designated ARAs working in registered firms are able to sign ATOL Accountants Reports.

ICAS is an Approved Professional Body for this scheme.

You can download the ATOL Newsletter that went out at the end of December to all ATOL holders.  This includes questions and answers regarding the ARA Scheme.

You can also download the latest version of the CAA's Guidance Note 10.

Why is the scheme being introduced?

The CAA has introduced the ATOL Reporting Accountants Scheme to ensure that accountants signing ATOL Accountants Reports are competent and experienced to conduct this work.

This has been introduced, in the public interest, to improve the quality of ATOL Accountants Reports on ATOL holders in order to reduce the likelihood that consumers buying from ATOL holders would be affected by insolvency and suffer inconvenience and financial detriment as a result.

Any accountant wishing to conduct this work will now require to be registered and designated by an Approved Professional Body, such as ICAS, to conduct this work.

For more background on the reason for this scheme please read:

Rebalancing ATOL:  CAA's decision on consultation proposals to ensure a fair and proportionate scheme PDF [832 KB]

Is my firm eligible to be registered?

Each firm must:

  • have Professional Indemnity Insurance at least sufficient to cover the Liability Cap in the CAA Guidance Note 10;
  • have a principal business of the provision of accountancy services;
  • be fit and proper and independent of the ATOL holder;
  • appoint an ATOL Contact Principal;
  • comply with the ICAS ATOL Reporting Accountants Regulations; and
  • have completed the firm application form, paid any Affiliate fees, and be granted registration by ICAS.

Each principal in the firm must be:

  • a member of one of the three Institutes of Chartered Accountants ; OR
  • a member of the Association of Chartered Certified Accountants; OR
  • a member of Association of Accounting Technicians; OR
  • an ICAS Affiliate.

Am I eligible to become an ATOL Reporting Accountant (ARA)?

Only licensed and registered ARAs will be able to sign ATOL Accountants Reports from 1 April 2016 onwards.

Each ARA must be:

  • be a member of an Approved Professional Body signed up to the ATOL Licensing scheme (ICAS, ICAEW, ACCA or AAT) or an ICAS Affiliate;
  • hold a Practising Certificate;
  • be an employee or principal of the registered firm;
  • can demonstrate sufficient experience in ATOL work;
  • can demonstrate a sufficient level of competence to carry out ATOL work;
  • have undertaken adequate CPD appropriate to maintaining and developing competence for an individual seeking to be an ATOL Reporting Accountant and have met the training requirements;
  • is fit and proper;
  • be able to demonstrate compliance with the ICAS Rules and Regulations; and
  • have completed an ARA application form, paid the ARA fees, and been granted ARA status by ICAS.

What are the training requirements?

The CAA requires all ATOL ARAs to have completed mandatory training by the CAA and, if you have not done so already, please apply for this training by emailing the CAA.  You will be asked to supply the following:

  • Name
  • Surname
  • Professional Accountancy Body (the body you are applying to for the ARA Scheme)
  • Member registration number (for reference to the PAB)
  • Email address - to be taken from the email response.

The CAA will be issuing two mandatory modules:  (a) ATOL licence holder training and (B) ARA specific training. At the time of writing, the CAA is still developing module (b) and we may need to grant licences conditional on completing module (b) if it is not available in time.

Please try to complete module (a) as soon as possible.  We will inform you when module (b) become available.

We will also issue our own ATOL training material in due course which all ATOL ARAs must complete.  This is likely to be video based training.  We will inform you when this is ready.

You are required, as part of your application, to confirm that you have read CAA guidance, including the most up to date version of Guidance Note 10.  This is currently being re-drafted by the CAA.  You will require to read the updated version once it becomes available.

How do we apply?

The following application forms will require to be completed.

  • An application for the firm   DOC [336 KB]: to register the firm;
  • An application for each ARA DOC [305 KB]: Section 1 of the form requires to be completed by the firm detailing each ARA applicant, each ARA then needs to complete a Section 2, which should highlight the ARA's experience and competence in conducting this type of work; and
  • An Affiliate application  DOC [203 KB]: for any principal in the firm who is not already an Affiliate and requires to be under the scheme.  Affiliates are required in the following circumstances:
    • A principal will require to be an Affiliate if they are not a member of one of the three Institutes of Chartered Accountants; members of the Association of Chartered Certified Accountants; or members of the Association of Accounting Technicians; and
    • An ARA applicant will require to be an Affiliate if they are not members of an Approved Professional Body signed up to the ATOL Licensing scheme (i.e. ICAS, ICAEW, ACCA or AAT).

For details of the fees, and any other queries about the application process, please contact Regulatory Authorisations on 0131 347 0286 or

What and who is the ATOL Contact Partner?

This is the principal in the firm that is responsible for ensuring that the firm and each ARA complies with the ATOL Reporting Accountant Regulations.  This principal should become knowledgeable on the requirements of the ATOL Reporting Accountant Regulations.

Are there any other requirements once registered and designated?

Each firm must:

  • comply with the Rules and Regulations, including the ICAS ATOL Reporting Accountant Regulations;
  • submit a completed ATOL Annual Return;
  • ensure that it has appropriate policies and procedures in place to comply with the Regulations and Guidance Note 10;
  • conduct an Annual Compliance Review, including a whole firm review (a review of the firm's policies and procedures) and a "cold file review" (a review of ATOL completed engagements) to ensure compliance with the ATOL Reporting Accountant Regulations and Guidance Note 10; and
  • submit to and cooperate with a monitoring visit.  ICAS will require to monitor each ARA within each firm at least once every six years.  We intend to conduct this as part of our Practice Monitoring Visit.

Each ARA must:

  • maintain competence and appropriate ATOL related CPD;
  • comply with the Rules and Regulations, including the ATOL Reporting Accountant Regulations and comply with Guidance Note 10; and
  • submit to an cooperate with a monitoring visit to the firm.

Professional Indemnity Insurance (PII) Requirements

The firm is required to have professional indemnity insurance (PII) cover in excess of the liability cap calculated by reference to the firm's ATOL holder client's licensable revenue limit or bond.  This requires to be in place prior to reporting on an ATOL holder.

The requirements are detailed in Annex 5 of Guidance Note 10.


  • Practice regulation

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