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HMRC internal manual

Senior Accounting Officer Guidance

Notifying Senior Accounting Officer details to HMRC: overview

A qualifying company, see SAOG11000, must notify the name of its Senior Accounting Officer (SAO) to HMRC. It must make a separate notification for each financial year for which it is a qualifying company.

To do this the company must give HMRC the notification in writing, see SAOG13200.

There can only be one person who is a company’s SAO at any one time but the company may have more than one SAO over the course of a financial year. The company must notify the details of all persons who have been its SAO over the course of a financial year.

The company can supply only one notification for a financial year. This means that it cannot make a notification to HMRC until the financial year has ended.

A group of companies may choose to make combined notifications of SAO details for all of the companies in the group. Thus a group of ten companies could provide, say, three notifications, one for a single company, another for three companies and the final one for the other six companies. Alternatively the group may want to provide a notification relating to one person who has been the SAO of a number of companies. Provided HMRC receives the necessary notifications any combinations are acceptable.

The company must notify HMRC

  • by the date it has to file its accounts for the same financial year at Companies House as determined by the Companies Act 2006 or
  • by any later time as allowed by HMRC.

A company should know who its SAO or SAOs were the day after the end of the relevant financial year. So a company should normally have no difficulty in notifying by the time limit which is determined by the accounts filing day.

Customer Compliance Managers (CCMs) or the Mid-sized Business Customer Engagement Team (CET) should be sympathetic to requests on rare occasions for short extensions to the date for notification. However, this should not become an expectation on behalf of the company and CCMs or the CET must certainly not allow extensions as a matter of course. An application for an extension by a company must allow sufficient time as is reasonable for the CCM or CET to receive, consider and provide a response in writing and also to allow sufficient time for the company to provide a notification by the due date if the application is refused. All requests for which the CCM or CET think an extension should be given must be discussed with a Deputy Director in Large Business or an Assistant Director in Mid-sized Business, see SAOG13400.

If the company fails to notify the SAO details to HMRC by the end of the allowed period, it will be liable to a penalty of £5,000, see SAOG18300, unless it has a reasonable excuse, see SAOG20000. If it has a reasonable excuse it must notify HMRC without unreasonable delay after the reasonable excuse ceases to exist.