“Professional clearance” is the letter a new accountant sends, with the client’s permission, to the existing accountant asking whether there is anything they should know before accepting the appointment. ICAEW calls it a professional enquiry and points out that “clearance” is a misnomer: the old accountant cannot give or refuse permission to act. Their job is to answer honestly and promptly, and the decision to accept rests entirely with the new accountant.
Why is a professional enquiry needed?
Clients are free to change accountant whenever they like. The enquiry exists to protect the incoming firm, not to obstruct the client. Section 320 of the ICAEW Code of Ethics sets out the procedure for both sides. The incoming accountant must decide whether there is any reason not to accept the work when they are asked to replace another accountant, when they tender for work held by another accountant, and when they are asked to do work that is complementary or additional to someone else’s.
Behind this sits the requirement to consider whether accepting the client creates threats to the fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. Talking to the previous adviser is the quickest way to find out about unpaid tax, accounting irregularities, an uncooperative client or a fee dispute before taking them on. This applies whether or not the existing accountant is qualified.
What must the incoming accountant do?
ICAEW’s helpsheet for incoming accountants describes three steps:
- Explain to the prospective client that you have a duty to contact the existing accountant and ask for their authority, preferably in writing.
- Ask the client to confirm the change to the existing accountant and to authorise them, preferably in writing, to cooperate with you.
- Write to the existing accountant asking for any information or circumstances that might affect your decision to accept, and list the handover information you need, such as prior year accounts and returns as filed, opening balances and any open HMRC correspondence.
Paragraph 320.5A2 of the ICAEW Code says the incoming accountant should not ask whether the existing accountant has reported suspicions of money laundering or terrorism. The enquiry also runs alongside, and does not replace, the firm’s own customer due diligence and the issue of an engagement letter. If the client refuses permission to contact the old adviser, ICAEW’s guidance is to ask why, record the answer and weigh it in the acceptance decision.
How should the outgoing accountant respond?
ICAEW’s helpsheet for outgoing accountants says that on receiving an enquiry you should:
- obtain the client’s permission, preferably in writing, before saying anything of substance, because the duty of confidentiality continues after the relationship ends;
- respond promptly;
- say so clearly if there is nothing the new accountant needs to know;
- if there is something, give the details. Saying that unspecified issues exist is not enough.
Paragraph R320.7 requires any information to be given honestly and unambiguously. ICAEW reports counsel’s advice that an existing accountant who passes on information damaging to the client has a strong measure of protection against a defamation claim, provided the statements are made without malice: only what is sincerely believed to be true should be stated, and reckless allegations avoided. A reply should be factual, not hostile.
If the client refuses consent, the outgoing accountant must not give a substantive answer but should tell the new accountant that consent has been refused. The exception is an audit or review engagement where the accountant withdrew because of the client’s non compliance with laws and regulations: paragraph R320.8 then requires the relevant facts to be passed on even without the client’s permission.
What if the old accountant does not reply?
The incoming accountant should chase and try other means such as a phone call. If there is still no answer after a reasonable time (ICAEW suggests possibly 14 to 30 days depending on the circumstances), paragraph R320.6A requires a further letter sent by a trackable method stating that the new accountant intends to accept in the absence of a reply within a specific and reasonable period. ICAEW regards anything under two weeks as unlikely to be reasonable. After that period the new accountant may assume there is no adverse comment, but paragraph R320.6 still requires other reasonable steps to obtain information about possible threats.
Where the previous accountant has died or cannot be traced, the new accountant should approach any alternate or the administrators of the estate, check the accountant’s professional body listing, make online and media searches about the client and ask the client directly about any regulatory or legal proceedings.
Can the old accountant hold things back over unpaid fees?
Not the reply itself. ICAEW is clear that outstanding fees are not a reason for failing to respond to a professional enquiry. The outgoing accountant may mention the fees owed in the reply, and a breakdown by invoice is sensible.
Records are a separate question. Paragraph R320.7C requires the outgoing accountant to deal promptly with any reasonable request to transfer records, but a particular lien may allow some client owned papers to be held until fees are paid, subject to strict conditions that exclude, for example, a company’s statutory books and accounting records. See accountants’ lien and client papers. Separately, paragraph R320.7D requires the outgoing accountant to provide information about the client’s affairs if its absence might prejudice the client and the client cannot provide it themselves. ICAEW says no charge should normally be made for this unless there is good reason, such as a significant amount of work retrieving archived files, or requests for copies of documents the client was already given.
What if there are tax irregularities or a suspicious activity report?
Paragraph R320.7B prohibits the outgoing accountant from disclosing whether one or more suspicious activity reports have been made, or making any other disclosure that could amount to tipping off. If the enquiry asks the question, it should not be answered either way. That does not remove the duty to tell the new accountant what they ought to know. ICAEW suggests a factual reference to the unresolved item, for example that the client has received rental income since a given date that has not yet been disclosed to HMRC and that full disclosure is needed for all affected periods. See suspicious activity reports for accountants and the obligations in PCRT.
How long does a typical change of accountant take?
Illustration only. A company director asks a new firm to take over from the next year end.
- Day 1. The new firm obtains the client’s signed authority and sends the enquiry letter, with a copy of the authority, asking for prior accounts, tax computations and the fixed asset register.
- Day 2. The old firm writes to the client, sends a copy of the enquiry and asks for confirmation that it may reply.
- Day 9. The old firm replies: no professional issues, £850 in fees outstanding for the last set of accounts, and copies of filed accounts and computations enclosed. It keeps its own working papers but provides the information the new firm needs to prepare opening balances.
- Day 10. The new firm completes its due diligence, issues an engagement letter and accepts.
Had the old firm not replied, the new firm would chase at around day 21 and send a trackable letter giving a further two weeks before accepting.
What are the common mistakes?
- Replying to an enquiry without the former client’s consent.
- Using the language of “clearance” or “permission”, which ICAEW says should not appear in a reply.
- Refusing to reply until fees are paid.
- Asking, or answering, whether a SAR has been made.
- Starting work, or filing returns, before the enquiry has been made.
- Hostile or vague replies that hint at problems without giving details.
For audits, the predecessor auditor must give the successor access to relevant information on a written request; ICAEW refers firms to AAF 01/08, Access to information by successor auditors.
Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.
Related Accountapedia entries
- A client onboarding process for accountants
- Reviewing the client base: which clients to let go
- Giving second opinions
- Disengagement letters
- Selling or closing an accountancy practice: regulatory steps
Sources
- ICAEW: Change of professional appointment incoming accountant
- ICAEW: Change of professional appointment outgoing accountant
- ICAEW: Responding to a professional enquiry
- ICAEW: Exercising liens
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.
