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Accountancy Practice Launch Programme · Stage 3 of 10
Get Compliant
Put the mandatory compliance in place so you can take on your first client lawfully, then take the detail from your body, HMRC, or a recognised proforma.
How long
1–2 weeks
You’ll have
AML supervision confirmed, the ICO fee paid, and your engagement letters ready
Steps
4 steps
Resources
2 resources
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01 Step 01
Step 01
Get AML supervised
Anti-money-laundering supervision is a legal requirement under the Money Laundering Regulations for anyone providing accountancy services by way of business. You cannot trade without it.
Do it yourself
- Find your route. If you hold a practising certificate or licence, your body (ICAEW, ACCA or AAT) supervises you for AML, so confirm you are registered with them and do not also register with HMRC.
- If you are unregulated, register with HMRC for money-laundering supervision before you start trading.
- Budget the HMRC fees: a £300 one-off application fee, £400 per premises each year, and a £40 approval (fit-and-proper) fee per beneficial owner or officer. A small-business reduction applies if turnover is below £5,000. Fees rose in December 2025, so verify the live figures on GOV.UK.
- Appoint your MLRO (in a solo practice, that is you) and write your AML policy, risk assessment and procedures.
- Diarise the annual declaration and fee so your supervision stays live.
Common mistake · Taking your first client before AML supervision is confirmed. Trading unsupervised is an offence, not a paperwork slip.
TimeHMRC registration takes ~2–4 weeks to approve Cost~£340–£740+ in year one, ~£400/yr after on the HMRC route (verify live on GOV.UK) DifficultyMediumResource for this step
CHECKLISTAML setup checklist
The steps from picking your supervision route to keeping it live, in order. A signpost, not advice.
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02 Step 02
Step 02
Register with the ICO and pay the data protection fee
You process personal and financial data, so you must be registered with the ICO and pay the annual data protection fee.
Do it yourself
- Use the ICO self-assessment to confirm your tier. A new practice is almost always Tier 1 at £52 a year (turnover under £632k, or ten or fewer staff), with Tier 2 at £78 and Tier 3 at £3,763. Confirm the current fee on ico.org.uk.
- Register and pay online, and set up Direct Debit for the £5 discount.
- Publish a privacy notice; your engagement-letter privacy section can double as this.
- Note your lawful basis for processing, and diarise the annual renewal.
Common mistake · Assuming a tiny solo practice is exempt. Accountants handling client data are not, and non-registration is enforceable.
Time~30 minutes Cost£52/yr at Tier 1 (confirm the current fee on ico.org.uk) DifficultyEasy -
03 Step 03
Step 03
Create your engagement letters and terms of business
Every professional body requires a signed engagement letter for each client, and it is your first line of defence in any dispute.
Do it yourself
- Start from a recognised proforma: the CIOT and ATT engagement-letter templates (produced with AAT and ACCA), and the ICAEW TAS helpsheet.
- Cover scope and exclusions, fees and payment terms, each party’s responsibilities, termination, limitation of liability, GDPR and privacy, and your position on holding client money.
- Use a schedule per service so you can add or remove services without rewriting the whole letter.
- Decide how you will get them signed: e-signature or engagement-letter software.
Common mistake · Starting work on a handshake and papering the engagement later. If the job goes wrong first, you are exposed on scope and liability.
Time~1–2 days to build your template set Cost£0 for proformas, up to ~£100–£300 for a template pack DifficultyMediumResource for this step
CHECKLISTEngagement letter toolkit
Every section a good engagement letter and terms of business should cover, and where to start from. A signpost, not advice.
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04 Step 04
Step 04
Set your professional conduct and ethics baseline
The fundamental principles (integrity, objectivity, competence, confidentiality and professional behaviour) govern how you must act, and members are held to them.
Do it yourself
- If you are a member, read your body’s Code of Ethics and note your CPD obligation, which is a condition of your practising certificate.
- Adopt a conflict-of-interest and confidentiality procedure, however lightweight.
- Set a competence gate: a rule for when you refer work out rather than attempt it, such as complex R&D claims or non-UK tax.
- Keep a simple CPD log from day one.
Common mistake · Treating ethics and CPD as a box-tick. Competence and confidentiality lapses are the most common route to a complaint or a claim.
Time~half a day, then ongoing CostFree DifficultyEasy
What you’ll have after this stage
- AML supervision confirmed, through your body or HMRC
- An AML policy, risk assessment and a named MLRO
- Your ICO data protection fee paid and a privacy notice published
- A signed engagement-letter and terms-of-business template set
- A conduct, ethics and CPD baseline you actually follow