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HMRC internal manual

Senior Accounting Officer Guidance

Who is a Senior Accounting Officer: overview

A Senior Accounting Officer (SAO) is the director or officer of a company who, in the company’s reasonable opinion, has overall responsibility for the company’s financial accounting arrangements.

Each qualifying company, see SAOG11100, must identify who its SAO is. The company’s opinion must be a reasonable one.

Except in very unusual circumstances a qualifying company will always have an SAO. Where a Customer Compliance Manager (CCM) or the Mid-sized Business Customer Engagement Team receives a claim that there is no SAO for a qualifying company, see SAOG16400.

The identity of the SAO can change, see SAOG12500.

Where a group of companies is involved, there may be

  • a different person who acts as SAO for each company,
  • a single person who acts as SAO for all the group companies or
  • several different persons who act as SAOs for different parts of the group.

Note that because the SAO must be a director or officer of the company, this responsibility cannot be delegated to an agent or advisor of the company. However where a company is in administration or liquidation, the administrator or liquidator may be the SAO. If they are not, they should be ‘the responsible person’ able to identify who is.

For the purposes of the SAO provisions, a company can only have one SAO at any stage.

It is in a company’s interests to identify who their SAO is at an early stage in their financial year. That person can then undertake the responsibilities set out in the SAO provisions.