# Accountancy practice readiness check: ten yes-or-no questions on MTD, AML, clearance and client records > Ten yes-or-no questions for a small UK accountancy or bookkeeping practice on MTD sign-up, AML supervision, new clients, records dates and leavers. - Page to cite: https://aeolookup.com/accountants/accountancy-practice-readiness-check/ - Publisher: AEO Lookup (https://aeolookup.com/) - Section: Accountancy practices, Running the practice - Published 1 October 2026 - Key fact: We wrote ten questions from the rules set out in 8 of our guides; for 4 of the ten the answer that is in order is "no", so the check cannot be passed by ticking yes. The first asks: Does every client's engagement letter give a date for sending records that falls before the filing deadline? A records date 18 days after each period ends (23 July, 23 October, 23 January and 23 April for standard MTD quarters) leaves the practice 15 days before the 7th. Records sent on the deadline leave none. - Sources: GOV.UK MTD quarterly update deadlines; GOV.UK Making Tax Digital for Income Tax guidance; GOV.UK "Add your client authorisations for Making Tax Digital for Income Tax"; GOV.UK "Authorise an agent for taxes that use the digital handshake"; GOV.UK "Fees you'll pay for money laundering supervision"; ICAEW Code of Ethics 2026, section 320; ICAEW Code of Ethics 2026, section 320; ICAEW helpsheet; Companies House identity verification guidance; Money Laundering Regulations 2017, regulation 40; ICAEW "Client disengagement" and "Disengagement letters" helpsheet; each rule is set out with its source in the guide the question links to. The test record is in tests/readiness/tools-check.txt. This check is for the owner or practice manager of a small UK accountancy or bookkeeping practice. The ten questions cover Making Tax Digital sign-up, anti-money-laundering supervision and records, taking on and letting go of clients, and the dates clients are given for their records. Each one comes from a rule set out in our guides, and tax advice and sign-off stay with the accountant. There are ten questions and they take about five minutes. Answer from memory. "Not sure" counts as a gap, because a rule nobody in the office can recall is a rule nobody is checking. **Free tool on the page:** Accountancy practice readiness check: ten yes-or-no questions on MTD, AML, clearance and client records. It runs in the browser at https://aeolookup.com/accountants/accountancy-practice-readiness-check/#tool and asks for no sign-up. ## What each question checks **1. Does every client's engagement letter give a date for sending records that falls before the filing deadline?** The answer that is in order is "yes". A records date 18 days after each period ends (23 July, 23 October, 23 January and 23 April for standard MTD quarters) leaves the practice 15 days before the 7th. Records sent on the deadline leave none. Source: GOV.UK MTD quarterly update deadlines. The working is in [How to stop clients sending records late](https://aeolookup.com/accountants/how-to-stop-clients-sending-records-late/). **2. Do you treat a client as outside MTD for Income Tax when their profit is under the threshold?** The answer that is in order is "no". The test is qualifying income: gross self-employment and property income added together, before expenses. A landlord with £28,000 of rent and a £24,000 side business is over £50,000 and has been in since 6 April 2026. Source: GOV.UK Making Tax Digital for Income Tax guidance. The working is in [MTD for Income Tax deadline checker](https://aeolookup.com/accountants/mtd-income-tax-quarterly-deadline-checker/). **3. Has the practice added every one of its Self Assessment agent codes to its agent services account?** The answer that is in order is "yes". HMRC recognises existing Self Assessment authorisations for MTD only once the agent code is added to the agent services account. Adding a code does not sign any client up; that is done one client at a time. Source: GOV.UK "Add your client authorisations for Making Tax Digital for Income Tax". The working is in [How to sign up a client for MTD for Income Tax as an agent](https://aeolookup.com/accountants/mtd-income-tax-agent-sign-up-client-authorisation/). **4. Does anyone in the practice sign in to HMRC with a client's own user ID and password?** The answer that is in order is "no". GOV.UK says an agent must never sign in with a client's credentials. Authorisation comes from a link the client accepts with their own sign-in details, and the link expires after 21 days. Source: GOV.UK "Authorise an agent for taxes that use the digital handshake". The working is in [How to sign up a client for MTD for Income Tax as an agent](https://aeolookup.com/accountants/mtd-income-tax-agent-sign-up-client-authorisation/). **5. Is the practice supervised for anti-money laundering, by a professional body or by HMRC, with the proof on file?** The answer that is in order is "yes". A practice supervised by one of the 14 listed professional bodies does not register with HMRC. A sole practitioner with one office who does register with HMRC pays £740 in the first year and £400 a year after. Source: GOV.UK "Fees you'll pay for money laundering supervision". The working is in [HMRC AML supervision for accountants and bookkeepers](https://aeolookup.com/accountants/hmrc-aml-supervision-fees-registration-accountants/). **6. When a previous accountant says they checked a new client's identity, do you skip your own check?** The answer that is in order is "no". ICAEW's code says client identification cannot be delegated to the existing accountant. The new practice does its own identity and risk checks, and should not ask the previous accountant whether theirs were carried out. Source: ICAEW Code of Ethics 2026, section 320. The working is in [Professional clearance letter template](https://aeolookup.com/accountants/professional-clearance-letter-template-accountants/). **7. If a professional clearance letter goes unanswered, do you send a second, tracked letter before accepting the client?** The answer that is in order is "yes". ICAEW's code requires a second letter by recorded delivery, stating an intention to accept the engagement. Its helpsheet says a reply period of less than two weeks is unlikely to be reasonable. Source: ICAEW Code of Ethics 2026, section 320; ICAEW helpsheet. The working is in [Professional clearance letter template](https://aeolookup.com/accountants/professional-clearance-letter-template-accountants/). **8. Do you know which directors of your company clients hold a Companies House personal code?** The answer that is in order is "yes". Identity verification has been law since 18 November 2025. A company cannot file its confirmation statement until every director has verified, and the statement is due within 14 days of the review date. Source: Companies House identity verification guidance. The working is in [Companies House identity verification](https://aeolookup.com/accountants/companies-house-identity-verification-accountants/). **9. Do you keep the identity documents of former clients indefinitely?** The answer that is in order is "no". Regulation 40 requires due diligence records to be kept for five years from the end of the client relationship. After that the personal data must be deleted, unless another law or legal proceedings need it. Source: Money Laundering Regulations 2017, regulation 40. The working is in [How long should an accountant keep client records? The legal minimums, and a retention schedule to copy](https://aeolookup.com/accountants/how-long-accountants-keep-client-records/). **10. When the practice stops acting for a client, does it send a written letter listing the filings still outstanding and their deadlines?** The answer that is in order is "yes". ICAEW calls a written disengagement letter best practice. It should cover the work done, what remains, the date each item is due, any further work the practice will do and the fees owed. Source: ICAEW "Client disengagement" and "Disengagement letters" helpsheet. The working is in [Disengagement letter template for accountants](https://aeolookup.com/accountants/disengagement-letter-template-accountants/). ## How to use the result The list under your score is a to-do list. Each line names the rule, where it comes from and the page that shows how to deal with it. Put a name and a date against each one. A gap that has an owner and a date is being handled; a gap that everyone knows about and nobody owns is how firms end up explaining themselves later. Do the check again each quarter, and again whenever a rule in this sector changes. Give it to a second person in the office without showing them your answers. Where the two of you disagree, the procedure is not written down clearly enough, and that is worth knowing whichever of you is right. A good score is not a certificate. The questions cover the points our guides cover, which are the ones that come up most often in a small firm; they are not every duty a firm has. This page is general information, not legal advice. Overlyft ![](https://aeolookup.com/img/d/ours-badge.png) sets up AI assistants for accountancy practices: they prepare drafts for a person to approve. They do not make a firm compliant, and none of the ten answers depends on them. --- ![](https://aeolookup.com/img/d/owner-line.png) General information for UK small firms, not legal, tax or financial advice.