Practising certificates

Revised guide to when PC is required – effective from 1 September 2024.

If you are still unsure whether you need a PC please contact the Regulatory Authorisations department by email at regulatoryauthorisations@icas.com.

Please note practising without a PC could result in disciplinary action.

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.

To be eligible to apply for a PC, a member must have obtained at least two years’ “appropriate experience”, in accordance with Regulation 3.9 of the Public Practice Regulations, since being admitted as a Chartered Accountant. Appropriate experience is defined as follows and may include:

3.9.1 experience gained in a role in accountancy or a related role in public practice, business, public service, or teaching;

3.9.2 experience gained as a Principal in countries where a Practising Certificate is not, or was not previously, required; or

3.9.3 in the case of a Member admitted under reciprocal arrangements with other professional bodies, appropriate experience gained as an employee or as a Principal after the date of admission to the professional body.

The requisite two years’ appropriate experience should normally have been obtained within the two years immediately prior to the application being submitted, although career breaks (for example, for maternity leave) will be considered.  Members who have been admitted to ICAS membership, via the Special Entrant route, are not required to have obtained two years’ “appropriate experience”.

The PC application process usually takes three to four weeks for straightforward applications.

Applications are normally dealt with by ICAS staff.  However, the requirement for a PC is overseen by the Authorisation Committee, which considers less straightforward applications.  If the Committee has to consider your application, the process may take longer as it meets six times a year.

Please note, if you are setting up in a new practice it may take some time to arrange professional indemnity insurance (PII) cover for your firm. We recommend you build this into your timescales and start arranging PII as early in the application process as possible. Further information, including a list of participating insurers can be found on our Professional Indemnity Insurance Guide.

In order to submit your application, you will be required to upload:

• CV
• Two years CPD (Your CPD should cover the two years immediately prior to your application.  As ICAS’ CPD operates as a calendar year, please submit CPD records for the calendar years  spanning the two years prior to application.  For example, if you applied in August 2024, you should provide CPD covering the period August 2022 to August 2024, which spans three CPD years.  Please upload a separate form for each CPD year.)
• Declaration of Compliance (If the practice is new, a Declaration of Compliance must be completed and uploaded.  If you are becoming a Partner/Director in an existing CA practice, and the firm already supplies ICAS with this information, a further copy is not required.)
• Insurers Schedule of Cover/Verification Note (As above, this is only required for new practices.)
• Technical reference (If possible, this should be from your present, or most recent, employer, and should include the referee’s job title, as well as brief details of the work undertaken.) *
• Character reference (This 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/will be working for.) *

* We require these to be two separate references.  Whilst it is preferable for referees to be ICAS members, it is not mandatory.  ICAS cannot accept references from a family member.  Please note, we do not have a template/preferred wording that you are required to be use.

• Any other supporting information (For example, additional information on why you require a PC or background on your current circumstances.  This information can be provided in two ways:  uploaded as an additional document (using the "Add Files" option on page 4 of the form); or you by entering the information into the "services / relevant experience" box (also on page 4).

The online PC application lists various reasons as to why you wish to apply for a PC.

• Setting up as a sole practitioner/sole director.
• Becoming a partner of a partnership, or a limited liability partnership, or a director of a limited company which is a practising firm.  (Please note you should only select this option if you are becoming a principal of the firm. Members with a courtesy title of “director”, as opposed to those who are directors of a limited company in the legal sense, should not tick this box.)
• Becoming an employee responsible individual in an audit firm.  (Please ensure your firm’s Audit Compliance Partner has written to inform ICAS your firm wishes to appoint you as a Responsible Individual, and that you have established with ICAS you have an Audit Qualification before you tick this box.  You can contact us at members@icas.com to check audit qualification details.)
• To enable me to hold an insolvency permit.
• Other.  (If you select this option, please provide any additional relevant information, for example, why you require a PC or background to your current circumstances.  This can be done by uploading an additional document (using the "Add Files" option on page 4 of the form); or by entering the information into the "services / relevant experience" box (also on page 4).

The application also asks you to detail the services you intend to offer and your relevant experience in this area.  In considering your fitness to practice, we require to ensure you have sufficient experience to conduct the services you intend to undertake.  In assessing your experience, the Regulation team will assess the experience you have noted in this section together with your CV and CPD.

Please note, the application cannot be submitted unless all required information and payment is included in the application.

The PC fee is an annual fee which changes on 1 October each year. Applications approved prior to 30 September will be required to make full payment of the current fee and will be invoiced in November for the following years fee.

Applications received after 1 October will automatically pay the following years fee.  This will cover the period up to 31 December the following year. For example, if you applied in October – December 2024, you would pay the 2025 PC fee, which would cover the period up to December 2025.  For details on the regulatory fees, please go to www.icas.com/regulation/regulatory-authorisations/icas-regulatory-fees.

ICAS has a defined policy for members’ annual subscription which is aligned to the Joseph Rountree Foundation Standard (JRFS) whereby a permanent discount is applied.  In recognition of the fact that the costs of practice for many members are a barrier for those who only wish to retain a few select clients, this policy also covers the PC fee in certain circumstances.

If you are returning to practice as a sole practitioner following a career break or starting up your first practice as a sole practitioner (or equivalent via a company), you may be entitled to a 25% reduction in the annual PC fee. The reduction is only available for members whose estimated gross fee income will be £28,000 or less for the year they are applying.  The 25% reduction will only be permanent if the member’s gross fee income remains under this threshold.  The reduction can be applied for as part of the online PC application.

In future years, your PC fee will be paid as part of your Annual Renewal.  If your gross fee income remains under the threshold, and you are still a sole practitioner, you will be eligible to apply for a reduced PC fee each year.  If the eligibility criteria still applies to you, once you have received your Annual Renewal, please email us at regulatoryauthorisations@icas.com to confirm this is the case.

Apply now

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.

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.