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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer main duty: reasonable steps: making delegations

A Senior Accounting Officer (SAO) may delegate some or all of the control and monitoring activities to other people. If so, in taking reasonable steps, we expect the SAO to think about and take account of the risks in delegating.

For example, the SAO might consider

  • the risk of delegating new or unfamiliar tasks and take steps to ensure that appropriate training is given to those involved
  • the risk of failure to carry out tasks or error in carrying out those tasks by the people they delegate to and take steps to monitor and control the activities of those people
  • the risk of other priorities or shortage of time preventing those they delegate to from carrying out the tasks and take steps to ensure appropriate resource is made available
  • where they are the SAO of the representative company of a group for VAT purposes the risk of delegating responsibility for VAT arrangements to those in other group companies, see SAOG14465.

If any of those risks materialise, the SAO should consider what can be done to mitigate them for the future.