Practising certificate Q&A: general

Question

I am an employee in a public practice with the functional title of ‘Tax Partner.’ I am not a statutory director (or member of the LLP). Do I need a PC?

Answer

It depends:

1. You need a PC if you are considered to be held out as a principal because: 
• there are no other professional accountants in positions of seniority or supervision over you within the organisation; or 
• the clients of the entity are otherwise led to believe that you are a principal. 
2. You do not need a PC if you are not considered to be held out as a principal and that it is clear on the firm’s website or elsewhere that you are not a principal in the practice or acting as a shadow director.

    

Question

I am an ICAEW member. My only role is as the marketing principal in a public practice. I do not provide accountancy services to any clients. Do I need a PC?

Answer

You need a PC. You are a principal in a public practice. Your personal role is irrelevant.

Question

I am a principal in an entity that only provides company secretarial services such as company formation, providing a registered office address and completion of confirmation statements. Do I need a PC?  

Answer

You do not require a PC. Company secretarial and other company services, such as company formation or providing a correspondence / registered office address are not considered by ICAEW to be accountancy or reserved services.

The Money Laundering regulations define businesses offering such services as Trust and Company Services providers (TCSPs). If you are offering TCSP services, by way of business, you must register for AML supervision because they fall within the scope of the Money Laundering regulations. We recommend you refer to government guidance on money laundering supervision for trust or company service providers.