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ATOL Reporting Accountants Scheme

The ATOL Reporting Accountants (ARA) 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.

Further information on the ATOL Reporting Accountants Scheme can be found on the CAA website. This includes questions and answers regarding the ARA Scheme.

You can download the latest version of the the Requirements for ATOL Reporting Accountants from the CAA website, as well as the Annual Accountants' Report, which is required to be completed as a term of holding an ATOL. The requirements, previously referred to as “Guidance Note 10” are now presented in Appendix A of the Official Record Series 3.

ICAS Guidance for ATOL

  • ICAS Revised Guidance for ATOL Reporting Accountants - January 2019

Why was the scheme introduced?

The ATOL Reporting Accountants' scheme has been developed by the Civil Aviation Authority (CAA) in order to help improve the standard of ATOL reporting and to provide assurance that financial information which is submitted on behalf of ATOL holders is accurate.

The Scheme  is designed to ensure that designated accountants of participating bodies are sufficiently knowledgeable about both the industry and specific requirements of ATOL to provide the required assurance needed by the CAA.

The scheme will ensure that the professional accountancy bodies provide the appropriate level of continuing professional development (CPD) in order to best equip their members to successfully undertake ATOL work. It also means that professional accountancy bodies will have in place a more professional regime that focuses on the demonstration of competence, helping to reduce overall risks in the market of reporting false or inaccurate financial information by ATOL holders.

Any accountant wishing to conduct this work is required 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 Requirements for ATOL Reporting Accountants;
  • 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
  • a member of the Association of International Accountants (AIA); Or
  • a member of the Institute of Financial Accountants; OR
  • an ICAS Affiliate.

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

Only licensed and registered ATOL Reporting Accountants (ARAs) are able to sign ATOL Accountants Reports.

Each ARA must be:

  • be a member of an Approved Professional Body signed up to the ATOL Licensing scheme (ICAS, ICAEW, ACCA, ICAI, AAT, AIA or IFA) 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 Civil Aviation Authority (CAA) requires all ATOL Reporting Acocuntants (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:

  • Forename
  • Surname
  • Professional Accountancy Body (PAB) (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 provide an online training module providing ATOL Reporting Accountants with background on ATOL. All accountants will be required to complete this training as part of their initial designation and the results of this training will be provided to the relevant professional accountancy body. There is a CAA webpage for ARAs that will be periodically updated on ATOL information, feature news, alerts, documents on revisions to guidance, or for subsequent changes to standards or regulations.

You are required, as part of your application, to confirm that you have read CAA guidance, including the most up to date version of The Requirements for ATOL Reporting Accountants.

How do we apply?

The following application forms will require to be completed.

  • An application for the firm: to register the firm;
  • An application for each ARA: 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 application for an affiliate ARA:
    • 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, ICAI, ACCA, AAT, IFA and AIA).

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

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 The Requirements for ATOL Reporting Accountants;
  • 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 The Requirements for ATOL Reporting Accountants; 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 The Requirements for ATOL Reporting Accountants; and
  • submit to an cooperate with a monitoring visit to the firm.

ATOL Reporting Accountant Regulations

Download the ATOL Reporting Accountant Regulations.
PDF [282 KB]

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 The Requirements for ATOL Reporting Accountants.

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