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HMRC internal manual

Senior Accounting Officer Guidance

From
HM Revenue & Customs
Updated
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Who is a Senior Accounting officer: where there is more than one in a financial year

SAOG12200 gives a description of the person who will be the Senior Accounting Officer (SAO) for a qualifying company. The SAO role can only be held by one person. It cannot be shared. There can therefore be only one SAO for a qualifying company at any one time.

However, it is possible for there to be more than one SAO for a qualifying company for a financial year. This will happen where at any time in the financial year and up to the final date for filing the SAO certificate for that financial year

  • there is a change of responsibilities or spread of those responsibilities due to re-organisation of the company’s governance arrangements, division of duties, merger/acquisition and so on or
  • there is a change of personnel during the financial year due to retirement, promotion, resignation and so on.
     

If there is a change of personnel but not a change of responsibilities, it should be straightforward for the company to identify the new SAO. It is usually the person who replaces the outgoing SAO.

If there is a change of responsibilities or spread of those responsibilities, the company must consider again which person within the company best fits the description in SAOG12200.

The company must make this identification as many times as are necessary for a financial year. This enables the person identified to carry out the duties necessary to satisfy the Senior Accounting Officer provisions.

However, no matter how many times the SAO may change in a financial year, a company needs to make only one notification of SAO details, see SAOG13000, and it should do that after the end of the financial year.