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HMRC internal manual

Senior Accounting Officer Guidance

Who is a Senior Accounting Officer: identifying a Senior Accounting Officer

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

A qualifying company, see SAOG11100, must identify who best fits this description. It must make a reasonable decision about this. In most cases it will be clear from the company’s governance arrangements: the SAO will be a person who has sufficient information and authority to fulfil their responsibilities.

HMRC may challenge the company if it believes that the company has not taken account of the description above and therefore has not formed a reasonable opinion of who its SAO is. The company’s opinion could be different from that of another person or HMRC, but if it was reasonable there are no grounds for HMRC to challenge it. See SAOG16300+ for further compliance guidance.

The role of the SAO cannot be filled by an agent - for example, the company’s external audit or accountancy advisers. The SAO provisions make this a key role and responsibility within the company or group. It cannot be out-sourced or assumed elsewhere.

A person may be the SAO of more than one company. A person may be the SAO for a number of companies within a group. Equally a person may be the SAO of a number of companies that are not within the same group.