Practice monitoring

Upholding standards is one of ICAS's main missions and is the main focus of ICAS Practice Monitoring.

The ICAS Practice Monitoring regime is designed support the work of its Practising Certificate holders by reassuring the public and other regulators that firms are complying with regulatory requirements.

What is covered on Practice Monitoring visit?

Practice Monitoring is not a statutory function and therefore the visits are designed to be consultative and helpful as opposed to prescriptive, the aim being to help firms to ensure that they are complying with relevant legislation, ICAS Rules and best practice.

With the exception of audit and insolvency which are monitored separately, Practice Monitoring covers all areas of accountancy practice.

A Practice Monitoring visit will typically focus on the following areas:

  • An overview of office procedures
  • Compliance with legislation and ICAS Regulations (primarily Money Laundering, Client Monies and CPD procedures)
  • Follow up on weaknesses noted at previous visits
  • Acting as a sounding board
  • Feedback from our firms indicates that members welcome the opportunity to discuss any relevant matters with the monitoring staff, and therefore, this vital aspect of the visit has been retained within the Practice Monitoring structure.

Who is required to receive a Practice Monitoring visit?

All ICAS members holding a Practising Certificate (PC) will receive a Practice Monitoring visit on a regular basis.  Rather than visiting PC holders individually it is more effective to visit a firm and all PC holders at the firm.  All offices of the same firm will, where practical, be covered within the same visit.

For CA members in practice with members of other accountancy bodies, there are reciprocity arrangements in place and, in most cases, only one body will visit the firm.

Who will conduct the visit?

The Practice Monitoring team consists of qualified Chartered Accountants who are employed by ICAS and have extensive experience gained in all areas of general practice, including taxation, accounting for owner-managed businesses, charity accounting, audit and corporate finance.  Additionally, as a number of PC holders are often engaged as peripatetic directors, we have reviewers who also have experience of work outside traditional general practice.

How are Firms selected for a visit?

A risk based approach to visit selection is applied, although all firms can expect to be subject to a Practice Monitoring Review from time to time.  The selection is based upon:

  • Risks identified from a review of information provided in the firm’s annual return
  • Risks and knowledge obtained from historic visits
  • Referrals made from other ICAS committees, departments or other regulators
  • Random selection from the Practicing community

How are Firms notified of a visit?

Firms are notified at least six weeks in advance of the review, and this notification sets out details of the proposed date, the proposed type of review visit and the name of the reviewer.

What if the date is unsuitable?

If the date proposed in the selection email is unsuitable, then the firm should contact the Visit Co-ordinator (0131 347 0284) within five working days of receipt of the notification.

Types of Reviews

Essentially there are three different types of review:

  • Telephone Calls
  • Desktop reviews
  • Onsite visits

Telephone Calls

The most straightforward of the review procedures is the telephone call.  Typically this delivery method will be appropriate when dealing with a small part-time practitioner with a small number of fairly straight-forward clients.

The practitioner is not required to submit any documentation in advance of the telephone review, although it is helpful if CPD records and PI insurance documentation is readily to hand in case it needs to be referred to during discussions with the reviewer.

The reviewer will normally agree on a suitable time to conduct the telephone review.

During the telephone call, the reviewer will discuss with the practitioner their approach to complying with the key regulatory areas.  No client work is reviewed as part of a telephone visit although the reviewer will likely discuss with the practitioner their approach to client work performed.

Any areas of non-compliance will be reported in the draft report that will is emailed following the telephone discussion. The practitioner is required to respond to the points raised in the report within two weeks of receiving it.

Desktop Reviews

Conducted off-site, the desktop review requires the practitioner to submit various documents to the reviewer about two weeks before the scheduled review date.  A list of required information is sent along with the visit notification.

Desktop reviews are aimed at small sole practitioners, typically with no staff or one or two part-time members of staff.

The reviewer will take the time to review all of the information provided, looking for evidence that the firm is complying with the various regulatory requirements. Normally a desktop review will include the review of at least one client file.

To conclude the desktop review, the reviewer will telephone the practitioner to discuss any questions arising and to summarise the observations made during the review.  Normally the reviewer will be in touch in advance to agree a mutually agreeable time to undertake the closing discussions.

A draft report will then be prepared and emailed to the practitioner for comment.  The practitioner’s comments are required within two weeks of receiving the draft report.

Onsite Visits

The majority of firms will receive an onsite visit. Indeed, if practitioners who have been selected for a desktop or telephone review would prefer a face to face review then this will be arranged.

An onsite visit comprises:

  • An initial opening meeting
  • The fieldwork, including a review of:
    • The firm’s policies and procedures
    • A sample of client engagement files
  • A closing meeting

The opening meeting allows the reviewer to discuss a variety of areas to establish the approach the firm follows in terms of regulatory compliance and client work.  It also allows the reviewer to gain an understanding into the type of work the firm is undertaking and how the work is carried out.

The areas reviewed during the fieldwork stage include:

  • File structure, standard documentation, consistency of approach, for example
  • Review of staff documentation such as CPD records
  • Adherence to Standards, Rules, Regulations and best practice guidance
  • Practice management in relation to client money, Anti-Money Laundering; Professional conduct such as ethics, investment business, etc.

Practice Monitoring is a risk based approach to monitoring and as a result the reviewer will determine the number of client engagement files and the type of files to be reviewed based on the perceived risks.

To conclude, the reviewer will carry out a closing meeting to discuss issues that have arisen and to provide guidance and pointers that may help improve the firm.

A draft report will then be prepared and emailed to the practitioner for comment.  The practitioner’s comments are required within two weeks of receiving the draft report.

Visit Closedown

All visits are independently quality reviewed to ensure that the visit methodology has been met, and that the visit conclusions are fair and balanced.

The Authorisation Committee includes members who are practicing Chartered Accountants, and makes the decisions on whether any follow-up action is required by the firm following the visit. The Committee is also responsible for referring any disciplinary issues to the ICAS complaints and disciplinary process. The Committee is also bound by confidentiality rules.

The full impact on a firm that will potentially be subject to follow-up action will be discussed by the reviewer during the visit.

The timing of when a firm hears about the outcome of a visit will depend on whether there is anything to follow up on post visit, or if registration will continue without any additional information being provided to the Committee. As the Committee only meets every two months, it may be some time before a firm receives notification of the decision.

If you are concerned about the delay in hearing back after the visit, please contact


  • Practice monitoring
  • Practice regulation

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