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HMRC internal manual

Senior Accounting Officer Guidance

Notifying Senior Accounting Officer details to HMRC: time limits for notification

A qualifying company must notify HMRC of the name of the person who has or persons who have been its Senior Accounting Officer (SAO) during 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.

However, the company must notify HMRC not later than the end of the period that is allowed by the Companies Act 2006 for filing the company’s accounts for the financial year at Companies House.

  • For public limited companies this is six months after the end of the accounting period.
  • For other companies this is nine months after the end of the accounting period.

For guidance on short or long periods of account, and changes to the period for filing under the Companies Act 2006, see SAOG13410.

A group of companies may choose to make combined notifications of SAO details for all of the companies in the group. The companies in a combined notification may have different filing dates because either they have different year ends or one may be a public limited company. In that case the combined notification must be provided by the earliest filing date of the companies involved.

The HMRC Customer Compliance Manager (CCM) or Mid-sized Business Customer Engagement Team (CET) can discuss notification time limits with the company in advance. Such a discussion will help both parties understand when a notification is likely to be made and, if appropriate, which companies it will cover.

Although the law allows HMRC to agree a longer period for notification, it is very unlikely that this will be necessary. A company will have at least six months after the financial year end to provide details that it will know at the financial year end. If, exceptionally, a company believes it needs more time to make the notification, it should write to the CCM or CET before the notification period ends to request an extension and explain why it is needed. The CCM or CET will consider each request on its own merits and, to ensure consistency, must discuss any proposed extension with

  • their Deputy Director in Large Business or
  • their Assistant Director in Mid-sized Business.

If an extension is agreed, the CCM or CET must confirm this to the company in writing.

FA09/SCH46/PARA3 (2)(b)