Practising certificates

Do services to charities, non-profit making organisations, and sporting organisations require a PC?

ICAS has recently reviewed the requirements to hold a PC in this area.

You are not considered to be engaging in practice and therefore do not require a PC if you provide accountancy services to small charitable, community, religious or sporting bodies, or to similar non-profit making bodies where:

• you are not conducting this work 'by way of business';
• you are conducting the work free of charge or for a nominal fee of £100 or less;
• there is a maximum of ten appointments;
• no audit is being undertaken; and
• any independent examinations conducted are for bodies with gross income of £500,000 or less.

If you do not require a PC, per the above guidance, but are providing independent examinations or other reporting services to charities on a voluntary basis, you should inform the trustees in writing that there is no PII in place.

Sample wording: "As a non-practising member of ICAS (i.e. I do not require to hold a practising certificate under ICAS' Rules and Regulations), I am required to inform you that there are no professional indemnity arrangements in place regarding the voluntary services which I am providing to AN Charity."

Any Member who does not require to hold a PC may still use the designatory letters 'CA' or the description 'Chartered Accountant' when signing an independent examination.

Please note that the position for Community Accountants is currently under review and that if you have a query in this respect, please contact regulatoryauthorisations@icas.com for the most up to date position.

Do trustees, treasurers, committee and board appointments need a PC?

You are not considered to be engaging in practice if you act as a trustee, treasurer, committee member or board member (except in the case that you are on the board or managing committee of an accountancy practice).

In these roles you are considered to be acting as an 'officer' of the entity in question and therefore are not 'in practice' and do not require a PC.

Frequently Asked Questions

I have been asked to undertake independent examinations for a number of charities.

It depends on whether you are paid for your services, how large the charity is, and how many appointments you have.

You will require a PC if the charity has a gross income of over £500,000.  This is because the charity is considered too large, and the risk is therefore too high, to be conducted by a member without a PC.  Whilst the audit exemption thresholds have recently been increased in England to gross income of over £1million, the audit exemption threshold for Scottish charities remains at £500,000.

A member who provides independent examinations to charities with a gross income of £500,000 or less can do so without a PC if:

• the services are free of charge or the services are for a nominal fee of £100 or less; and
• there are no more than ten appointments in total.

You cannot conduct any audit work for a charity without holding a PC and being formally designated as a Responsible Individual.

I have been asked to prepare SORP accounts for a number of charities.

It depends on the nature of your appointment.  If you are conducting this work under an employment contract then no PC is required.

If you are not an employee, the same considerations apply as the previous example.  A member who provides accounts preparation services to charities (or to a communal or sporting body, or to other similar bodies) can do so without a PC if:

• the services are free of charge or the services are for a nominal fee of £100 or less; and
• there are no more than ten appointments in total.

I have been asked to do the book-keeping for a number of charity and voluntary organisations including a playgroup.

The same considerations apply as the previous example.

I am retired and a trustee of a charity which involves preparing the charity's accounts.

Because a trustee is an officer of the charity and there is no remuneration, there is no requirement to have a PC; however, the trustee may wish to ensure that there is trustee indemnity insurance in place or personally arrange PII.

Note: any Chartered Accountant, even where otherwise retired, would be expected to undertake Continuous Professional Development for such a role. Further information can be found by searching 'CPD' on icas.com.

I am an unpaid volunteer at the Citizens Advice Bureau (or a similar charity).

The definition of being in practice includes being remunerated and so advice given in the capacity as an unpaid volunteer does not require a PC.

The PC application process usually takes three to four weeks for straightforward applications. For employee Responsible Individual applications or members joining an existing firm, the ICAS team will aim to process your application form within two weeks of receipt.

For PC applications involving a new practice set up, applications may take upwards of four weeks, primarily because of the time that the firm will need in obtaining PII quotes, and organising PII. If you wait until you submit your PC application you may find that it will take a number of weeks to organise PII and that this could hold up your application.

You are advised to start arranging PII as early on in the application process as possible in order to speed up the application process.

If you would like to apply for a PC you will need to:

• Complete and submit an Practising Certificate Application Form
• Enclose an up-to-date CV (to consider whether you have relevant experience in the areas you intend to provide to the public)
• Provide information on your firm's professional indemnity insurance (PII). More information on PII can be obtained from ICAS
• Submit one character reference and one technical reference (It is preferred that the references are from ICAS members, but it is not mandatory. The technical reference should be from your present, or most recent, employer, and should include the referee's job title.  It should contain details of the work undertaken for the referee. The character reference should be from an independent external source, such as a friend or client. It should be someone outside of the firm you have been working for or will be working for.)
• Pay the required PC fee (to be advised by ICAS)

The Practising Certificate application form asks for details in a number of areas:

Nature of Services to be offered and relevant experience (Section 5A)

This section of the form requires you to set out in the table the services you intend to undertake and the relevant experience you have had in that service area. In considering your fitness to practice, we require to ensure that you have sufficient experience to conduct the services you intend to undertake. In assessing your experience the Regulatory Authorisations team will assess the experience you have noted in Section 5A and have included on your attached CV.

Two Years CPD (Section 5B)

You are required to submit CPD records for the two years immediately prior to this application in order that we can assess whether you have maintained sufficient CPD to ensure that you have kept up to date.

As ICAS operates CPD on a calendar year basis, you will be required to submit the CPD records for the calendar years that span the two years prior to application. Your application cannot be progressed without this information.

Professional Indemnity Insurance (PII)

Information relating to professional indemnity insurance (PII) is included as part of the PC application pack. PII is compulsory for all members who have a practising certificate and are engaged in public practice. Evidence of PII held must be supplied before a member can be granted a practising certificate.

If you are joining an existing practice, and that practice has already supplied ICAS with a completed Declaration of Compliance, a further copy is not required. You will simply be asked to confirm that you will be covered by that firm's PII policy.

If the firm is a new firm a Declaration of Compliance form MUST be completed and returned. The requirements regarding PII are contained in Part 4 of the Public Practice Regulations. As a PII policy can take up to 28 days to finalise, the PC application form can be marked to indicate that the PII details will follow in order for us to proceed with the rest of the application. Please note, however, that your practising certificate cannot be sent to you until we have received a completed Declaration of Compliance form.

If your application involves a new practice start-up we advise you to start obtaining PII quotes and start to organise your PII as soon as possible before submitting the PC application. If you wait until you submit your PC application you may find that it will take a number of weeks to organise PII and that this could hold up your application.

In order to protect the public we are required to ensure that you are first assessed as 'fit to practice' before granting you a practising certificate.  This assessment includes a number of important checks.  The main checks are:

• Fit and proper checks: we require to ensure that there are no fit and proper issues.  We will check with our Investigations department whether you have any discipline history that might affect your application.  We also subscribe to the Financial Conduct Authority's Shared Intelligence service (SIS) and conduct a SIS check on all applications.  We will also ensure that your character reference is in order.
• Experience & Technical Knowledge: we require to assess whether you have the necessary experience and competence to conduct the services you intend to conduct. As part of this assessment we will consider your career history on your CV, Sections 5 and 6 of the application form, your CPD records and your technical reference.
• Public protection: we will ensure that if you are a Sole Practitioner and hold Clients' Money that you have appointed a suitable Alternate.  We also require to ensure that your practice activities will be covered by appropriate PII which meets the requirements of our Public Practice Regulations.

For employee RI applications or members joining an existing firm, the ICAS team will aim to process your application form within two weeks of receipt.  For PC applications involving a new practice set up, applications may take approximately 4 weeks, primarily because of the time that the firm will need in obtaining PII quotes, and organising PII.

ICAS' Authorisation Committee may need to consider your application.  This may take longer as the PPC meets only four times a year.  Please let us know if your application is urgent and requires to be expedited.

If you have not provided all of the information required we will contact you to request this information. This could delay your application being processed. We will let you know how this affects your application timescales.

We are here to help.  If you would like to know the status of your application please phone or email at the Regulatory Authorisations contact details above.

Once you have a PC there are a number of obligations that you will need to fulfill. We are here to help, so please contact us if you would like advice or support. You will need to meet the following requirements:

• Comply with the Public Practice Regulations PDF [134 KB]
• Comply with CPD requirements annually;

Your PC requires to be renewed annually and this is now done through your Members Annual Return.  You will be notified that the return is ready to complete around November each year and the deadline for submission is usually 31 December each year.

Only the Authorisation Committee can take the decision to reject a PC application. We will communicate to you the concerns raised by the Committee and what actions you can take in order that you can re-apply in the future. The majority of rejections relate to a lack of recent relevant experience and we will provide advice to you on ways that you can obtain the relevant experience before re-applying going forward.

Help and Support 

If you have any enquiries regarding Practising Certificates or Professional Indemnity Insurance please contact us by email on regulatoryauthorisations@icas.com or 0131 347 0286.

If you are not happy with the service you have received from us in respect of your applications please contact us via telephone on 0131 347 0100 or emailing us at members@icas.com.

In accordance with the requirements of the EU Service Directive, which was brought into UK law by The Provision of Services Regulations 2009, information is available about the rules, regulations and formalities that apply to service activities in other EU countries. This information can be found through Points of Single Contact (PSCs), which are online e-government portals. Guidance is available on the UK Government's website.