Obtaining a licence for CAA-ATOL returns
From 1 April 2016, the Civil Aviation Authority (CAA) will only accept reports only from members of professional bodies who have been designated to perform ATOL reporting with their professional accountancy body under the CAA Scheme.
The ATOL Reporting Accountants' (ARA) scheme has been developed by the CAA to help improve the standard of ATOL reporting and to provide assurance that financial information submitted on behalf of ATOL holders is accurate.
Only accountants who are designated by their professional bodies as an ATOL Reporting Accountant (ARA) will be authorised to sign CAA returns for their clients who hold ATOL licences.
Further information on the ARA scheme is available on the CAA website.
Accountants wishing to undertake CAA/ATOL reporting work are required to register with, and have a licence issued by, the IFA or another professional body approved by the CAA.
The IFA has decided that this licence will not require an additional fee for members. In order to obtain a licence from the IFA, you will need to apply to become an IFA member.
In order to apply for a licence to conduct ATOL reporting work, accountants must:
- Complete the application form to become a designated ATOL reporting accountant (licensed practitioner).
- Be a member of the IFA and hold a practising certificate granted by the IFA.
- Have successfully passed a professional examination/module covering assurance work.
- Have successfully passed the CAA ATOL training package.
- Agree to adhere to the IFA’s licensing rules for this type of work.
- Have reviewed the ATOL guidance issued by the CAA, including but not limited to Guidance Note 10 - Advice for Accountants, which includes reference to the liability cap.
To become a licensed firm for ATOL returns, please complete the licensed firm application form.
Please note that:
- sole practitioners must complete the designated ATOL reporting accountant and licensed firm application forms; and
- the IFA can currently only license firms which are 100% owned by IFA members.
The CAA’s eligibility criteria includes that the accountant must be able to demonstrate that they have taken and passed a professional examination covering assurance work as approved by the CAA (this may be limited to accountant modules of a professional qualification).
For ACCA members this is F8 Audit and Assurance or P7 Advanced Audit and Assurance, or previous equivalents. For ICAEW members this is certificate level assurance module of the ACA qualification.
If you have not passed a professional examination covering assurance work but would like to apply for a licence for this type of work, you may want to consider registering as a student of the ICAEW to sit the computer-based assurance assessment.
There is a one-off student registration fee of £165 +VAT, an examination fee of £70 and the cost of the learning materials is £30. If you would like to register for the ICAEW assurance module, please contact the IFA membership department by email firstname.lastname@example.org.
Accountants must register and complete the ATOL holder training module required by CAA prior to the granting of the licence by the IFA.
To apply to do the online ATOL training module, IFA members need to email the CAA (with the following information: name, surname, email address, professional accountancy body and membership number).
If you have not completed the course, you can still submit your application to the IFA, including the date when you expect to complete the course. Once you have completed the course, please email the pass certificate to the membership department or post to the IFA, CS111, Clerkenwell Workshops, 27-31 Clerkenwell Close, Farringdon, London EC1R 0AT.
In addition to the ATOL licence holder training currently available, CAA are developing online training for ARA. Both training modules will be mandatory for ARAs. At the time of writing, the ARA specific training module is not available but we will let you know when it is.
IFA licensing requirements
The agreement between IFA and CAA states that ‘IFA will designate and regulate ARA firms and ARAs in accordance with the provisions within the IFA Regulations and in full compliance with the requirements of the CAA’s ARA Scheme Key Components document and which forms part of this agreement’. Therefore, the IFA licensing arrangements are built on existing membership and professional development requirements.
Obligations of the designated ATOL reporting accountant/firm
The designated ATOL reporting accountant (ARA) must:
- Be a member of the IFA and hold an IFA practising certificate.
- Be an employee or principal of the registered firm (if you are a sole practitioner you are the principal of the firm).
- Comply with IFA's Bye-Laws, Code of Ethics and Regulations.
- Comply with the provisions of the licensing arrangement.
- Be independent of the ATOL holder.
- Demonstrate sufficient experience and level of competence to conduct ATOL work.
- Have undertaken adequate CPD appropriate to maintaining and developing competence for an individual seeking to be an ATOL reporting accountant and have met the training requirements. This includes successfully completing the CAA ATOL training package (as updated from time to time) and the training package assessment has been shared with the IFA.
- Have taken and passed a professional examination covering assurance work (this may be limited to accountant modules of a professional qualification but must include an assurance qualification).
- Have reviewed and follow guidance (including but not limited to Guidance Note 10 - Advice for Accountants issued by CAA ATOL (please note that a revised Guidance Note 10 is expected to be issued soon by the CAA).
- Meet the continuing professional development guidelines of the IFA.
- Inform the IFA’s membership department by email if they no longer wish to be a designated ATOL reporting accountant. It should be noted that the accountant still has obligations to deal with enquiries or complaints relating to the period when they were a designated ATOL reporting accountant.
The firm must:
- Provide accountancy services.
- Conduct only those services permitted under the terms of the licence when acting under the licence.
- Comply with IFA's Bye-Laws, Code of Ethics and Regulations.
- Comply with the provisions of the licensing arrangements, which includes submitting an annual return
- Communicate promptly to the IFA any changes that might affect the firm/ATOL Reporting Accountant eligibility to conduct this type of work or any firm changes such as, but not limited to, changes in the addresse(s), trading name(s), names and contact details of the principals of the practice and changes relating to the designated ATOL Reporting Accountant. This type of communication should be sent in writing to the IFA no later than 10 business working days after taking effect to IFA’s membership department email@example.com.
- Appoint a contact principal who will be responsible for communicating with the IFA, ensuring that the firm complies with the licensing arrangements for ATOL reporting work and conducts annual compliance reviews in the firm.
- Be independent of the ATOL holder as required by Section 291 of the IFA’s Code of Ethics.
- Have Professional Indemnity Insurance (PII) that is at least sufficient to cover the liability cap in the CAA Guidance Note 10 Appendix 5 (the current liability cap ranges from £250,000 to £20,000,000).
- Maintain an appropriate level of competence in the conduct of ATOL work and this is best achieved through the use of relevant policies and procedures, manuals, work programmes, checklists, internal compliance reviews, firm-wide training and fit and proper declarations. Such documentation must be kept up to date if the firm is to retain its competence.
- Make arrangements so that all members, principals and employees performing ATOL-related work are, and continue to be, competent to carry out ATOL reporting for which they are responsible or employed.
- Issue a letter of engagement to its ATOL clients outlining the nature, scope and terms of the service being provided and this should be kept as evidence of agreement by the client.
- Keep appropriate records of work undertaken on behalf of its clients for at least six years, or longer depending on legislation. These records can be held on paper or digitally.
- Notify its clients of the named person in the practice to be contacted in the event of a complaint and of their right to complain to the IFA. This information can be included as part of the engagement letter.
- Review, at least once a year, its compliance with the licensing arrangements and guidance by the CAA and take action when issues are identified.
- Inform the IFA in writing if the firm no longer wishes to have a licence to conduct ATOL reporting work. It should be noted that the firm still has obligations to deal with enquiries or complaints relating to the period of the licence.
- Co-operate with the IFA in monitoring visits.
IFA obligations and rights
The IFA will:
- Deal openly and fairly with firms/ATOL reporting accountants.
- Consider any applications under licence based on the information provided and the criteria required by the CAA in the ARA scheme. The IFA has sole discretion as to whether or not to issue the licence to the firm/ATOL Reporting Accountant.
- Conduct monitoring desk-top reviews/visits of licensed firms/ATOL reporting accountants as part of its overall monitoring process.
- Use the information in the firm’s annual return and the accountant’s annual declaration in their assessment of licensing the firm and designation of the accountant as an ATOL reporting accountant.
- Communicate with the proper authorities such as the CAA regarding regulatory and disciplinary matters.
The IFA will determine whether a firm/designated ATOL reporting accountant is liable to disciplinary action under the IFA’s disciplinary arrangements if they:
- in the course of carrying out ATOL reporting work or otherwise, have committed any act or default likely to bring discredit on themselves, the IFA or the profession of accountancy; or
- have performed ATOL reporting work inefficiently or incompetently to such an extent, or on a number of occasions, as to bring discredit on themselves, the IFA or the profession of accountancy; or
- have committed a breach of the IFA Bye-Laws, Code of Ethics and Regulations; or
- have breached any of the provisions of the licensing arrangement.
See the disciplinary process for further information.