Bookkeepers can offer clients protection against HMRC enquiry costs, but the regulatory route is different from chartered and certified accountants. AAT, ICB and IAB are not designated professional bodies under the Financial Services and Markets Act 2000, so their members cannot use the exempt professional firm route. A bookkeeping practice needs FCA authorisation, or to act as an appointed representative or introducer appointed representative of an authorised firm, or to use a model where the practice insures its own fees.

Which professional bodies can license firms to distribute insurance?

The designated professional bodies are set by the Financial Services and Markets Act 2000 (Designated Professional Bodies) Order 2001 and its amendments, and listed in the FCA’s Professional Firms sourcebook (PROF 2 Annex 1G). They include ICAEW, ICAS, Chartered Accountants Ireland and ACCA, along with the law societies, the Council for Licensed Conveyancers, RICS and the actuarial profession. AAT, the Institute of Certified Bookkeepers (ICB) and the Institute of Accountants and Bookkeepers (IAB) are not on the list, and nor is the Chartered Institute of Taxation.

What routes are open to a bookkeeping practice?

  • FCA authorisation in its own right, which is rarely proportionate for a small practice.
  • Appointed representative. An authorised principal takes regulatory responsibility for the insurance activities it agrees to, which can include arranging general insurance.
  • Introducer appointed representative. The FCA Handbook limits this to “effecting introductions” and “distributing non real time financial promotions”. The practice introduces clients and the authorised firm does the rest.
  • Insuring the practice’s own fees. Under this model, described in ICAEW’s helpsheet on fee protection insurance, the practice is the policyholder and insured, and the engagement letter keeps the work at the practice’s discretion and the client liable for its fees. Take advice before relying on it.

The usual exclusion for introducing people to authorised firms does not extend to arrangements for contracts of insurance (Regulated Activities Order, article 33), so even a simple referral of insurance business needs one of these routes.

What about commission?

AAT’s Code of Professional Ethics (section 240.6) says a member is accountable to the client for commission or reward unless the client, having been told its nature and amount, agrees the member can keep it. Check the current version of your body’s code, and any requirements of the authorised firm you work with.

What should a bookkeeper avoid?

  • promising to cover the cost of any future HMRC enquiry for a flat fee, which ICAEW describes as “effectively writing an insurance contract”;
  • making bookkeeping services conditional on taking cover;
  • describing cover loosely, or implying it pays tax or penalties.

Who supervises bookkeepers for anti money laundering?

AAT, ICB and IAB are listed as professional body supervisors in Schedule 1 to the Money Laundering Regulations 2017. The government has decided the FCA will become a single supervisor for professional services, subject to legislation. See AML supervision for accountants.

How can Solar Protect help?

Solar Protect builds fee protection schemes for accountancy and bookkeeping practices and can explain the arrangements available. See how our schemes work, and read how to run a fee protection scheme and explaining fee protection to clients. Clients who want cover in their own name can get a quote.

Related guides: fee protection rules by professional body.

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 7 October 2026. Sources: FSMA 2000 (Designated Professional Bodies) Order 2001 and amending orders; FCA Handbook PROF 2 Annex 1G and Glossary; Regulated Activities Order 2001 article 33; Money Laundering Regulations 2017 Schedule 1; AAT Code of Professional Ethics. This guide is general information, not legal or regulatory advice.