ICAS publishes new practising certificate guidance
ICAS is introducing new guidance on 1 September to help members understand if they need to hold a practising certificate.
ICAS’ Rules and Regulations require members to hold a practising certificate (‘PC’) if they satisfy one of two conditions:
1. They are being paid to provide accountancy or related services to someone other than their employer.
2. They are a principal (partner, director etc) in a firm providing accountancy or related services (or are being held out as a principal).
While it will normally be straightforward to identify whether a PC is required, there are grey areas where the requirement may not be clear. To help members understand whether they need to apply for a PC, ICAS publishes guidance providing more information on the requirements.
In September, a new version of the guidance will come into force, following recent approval by ICAS’ Authorisation Committee. While most of the content is substantially the same as the previous version, there are some important changes which members should be aware of:
- Geographic coverage – confirmation that the PC requirement can be triggered by either the member or the client’s location.
- Incidentality – provisions have been removed where it was previously unlikely that a PC would be required if the accountancy services provided are incidental to the core work of a firm.
- Sub-contracting – while arrangements will continue to be considered on a case-by-case basis, there is a stronger emphasis on a PC being required.
- AML – where a member’s work requires AML supervision, it is more likely that a PC will be required.
These changes have been made following an internal review of issues identified with the previous guidance, and in particular to address tension which has arisen where a member’s work did not require a PC but was legally required to be supervised by ICAS for AML purposes. The revised guidance also aligns ICAS more closely with similar guidance recently introduced by ICAEW.
While the guidance provides as much information as possible, including a list of common scenarios, it can’t cover every situation. As such, members who are in any doubt about the PC requirement should contact ICAS’ Regulatory Authorisations Team: regulatoryauthorisations@icas.com
