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HMRC internal manual

Senior Accounting Officer Guidance

Who is a Senior Accounting Officer: where a company is a member of a group

The process for identifying a Senior Accounting Officer (SAO) where a company is a member of a group is the same as that set out in SAOG12200. The responsibility for identifying an SAO lies with the responsible officers of the company. They must form a reasonable opinion of who the SAO is.

Where a qualifying company is a member of a group, the SAO for any one company may fulfil the SAO role for some or all of the UK companies within the group providing that

  • they are an officer or director of any company within the group or any group body corporate and
  • they do have overall responsibility for the company’s financial accounting arrangements.

A UK-owned group or the UK companies within a foreign-owned group may therefore have

  • one SAO with responsibility for all of the individual group companies or
  • more than one SAO, each with responsibility for a company or several companies.

The number of SAOs within a group will depend on the structure of the group and the spread of the financial accounting responsibilities.

It does not matter whether the SAO is located or resident within the UK or overseas.