If you are an AAT professional member and want to provide self-employed bookkeeping or accountancy services to the public, or you are joining an existing practice as a principal, in the UK, Channel Islands or Isle of Man, you must hold a valid AAT licence and be supervised for anti-money laundering compliance as required by the Money Laundering Regulations 2017. You’ll also need a licence if you’re working as either:
- a sole practitioner, or
- a partner, or
- a director or principal with at least 5% shares belonging to you, your household or your family.
While all AAT professional members who offer self-employed services fall under one of these categories, there are a few exemptions that are shown below.
Being authorised and regulated by a chartered and certified accountancy body
If you are authorised and regulated by a recognised chartered and certified accountancy body, you are not required to obtain an AAT licence. A list of bodies is outlined in the Licence exemption policy.
Providing services to another accountancy firm on a subcontractor basis only
If you are providing services on a subcontractor basis only, you do not need an AAT licence. However, you must ensure:
- you are covered by either the subcontracting accountant’s or your own Professional Indemnity Insurance;
- you have been trained and have an understanding of the anti-money laundering policies, procedures and controls in place at the firm;
you have a subcontracting agreement in place, clarifying your role and responsibilities along with the agreed PII and money laundering compliance arrangements in place.
Providing services on a voluntary basis
If you are a professional member but are only undertaking self-employed work on a voluntary basis to family/friends, a small charity or a non-profit-making entity, you do not need an AAT licence. You are able to help out in this way providing the following conditions are adhered to:
- you must only provide services in areas where you hold appropriate knowledge and experience
- you must not earn any remuneration from your work except the reimbursement of reasonable expenses
- you must not represent yourself as an AAT licensed member or being in public practice
- you must advise clients whether you hold Professional Indemnity Insurance cover at the outset of any work undertaken
- you must follow all AAT member regulations and policies including complying with our CPD policy and Code of Professional Ethics.
What to do if you think you’re exempt
As an AAT professional member, it is your responsibility to familiarise yourself with AAT’s licence requirements and determine whether or not you should hold a licence and be supervised for anti-money laundering compliance. If you are exempt from requiring an AAT licence, you must complete and return the licence exemption application immediately if you are providing services.
If you are unsure about the Licence exemption policy and if it applies to you, please email us or call us on +44(0)20 3735 2434 for further guidance. Our lines are open Monday to Thursday 9.00–20.00 and Friday 9.00–17.00 UK time.