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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer must provide a certificate to HMRC: time limits for providing the certificate

Normal time limit

A Senior Accounting Officer (SAO) must provide HMRC with a certificate no later than the end of the period allowed for filing the company’s accounts for the financial year with 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 SAOG15710.

The HMRC Customer Compliance Manager (CCM) should consider discussing the time limit for providing the certificate with the SAO in advance. Such a discussion will help both parties understand when the certificate is likely to be provided and, if appropriate, which companies it will cover. (Note that for Mid-sized Business customers such a discussion is less likely to take place.)

To meet the time limit, the SAO must provide the certificate on paper or in an acceptable electronic format (see SAOG15600) by the due date.

Allowing more time

The law allows HMRC to agree a longer period for the SAO to provide a certificate and CCMs or the Mid-sized Business Customer Engagement Team (CET) should be sympathetic on rare occasions for short extensions to the date for providing the certificate.

If, exceptionally, an SAO believes they need more time to provide a certificate, they should write to the CCM or CET before the normal certificate time limit to request an extension and explain why it is needed. The CCM or CET may, for example, consider allowing more time during a merger or acquisition situation or where there is some other major change affecting the company, its systems or the personnel who are key to the systems and governance.

It may be that the SAO may be unable to provide the certificate for personal reasons such as a death in the family, illness or hospitalisation.

An application by an SAO 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 SAO to provide a certificate by the due date if the application is refused.

Any decision to allow more time cannot be taken by the CCM or CET in isolation. 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 SAO in writing.

More time not allowed

CCMs or the CET must not allow more time simply because an SAO wants to submit one certificate covering a number of group companies whose financial years do not end on the same day. Companies and groups will be aware that the year ends are not coterminous and this situation does not arise from a sudden or unexpected event. SAOs should plan to provide a certificate to ensure that they meet the time limit for any particular company. This will be the date that the earliest certificate needs to be provided. If this is not possible the SAO can provide separate certificates.

FA09/SCH46/PARA2 (3)(b)