# Taking on and letting go of a client: ten yes-or-no questions for an accountancy practice > Ten yes-or-no questions on the practice's own duties at each end of a client relationship: the enquiry, checks, engagement letter, records, fees and HMRC. - Page to cite: https://aeolookup.com/accountants/taking-on-and-letting-go-of-a-client-accountants-self-check/ - Publisher: AEO Lookup (https://aeolookup.com/) - Section: Accountancy practices, Onboarding and AML - Published 2 October 2026 - Key fact: We wrote ten questions from the rules set out in 7 of our guides; for 5 of the ten the answer that is in order is "no", so the check cannot be passed by ticking yes. The first asks: Before writing to a new client's previous accountant, do you get the client's permission, preferably in writing? Section 320 of ICAEW's code says the incoming accountant needs the client's permission to write, preferably in writing, and the existing accountant needs the client's consent to answer. Without the signed authority the enquiry cannot be answered. - Sources: ICAEW Code of Ethics 2026, section 320; ICAEW helpsheet for the incoming accountant; GOV.UK, Your responsibilities under money laundering supervision; Money Laundering Regulations 2017, regulation 28(11); ICAEW guidance on document retention; Money Laundering Regulations 2017, regulation 40; ICAEW guidance on documents and records; Companies Act 2006, sections 386 and 388; ICAEW helpsheet for the outgoing accountant; GOV.UK, Change or remove your authorisations as a tax agent; Companies House identity verification guidance; 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. It covers the practice's own duties at the two ends of a client relationship: the enquiry to the previous accountant, the due diligence file and the engagement letter on the way in, and records, unpaid fees, the next accountant's enquiry and HMRC access on the way out. Each question comes from a rule set out in one of our guides, most of them from ICAEW's code and helpsheets, so members of other bodies should check their own. 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:** Taking on and letting go of a client: ten yes-or-no questions for an accountancy practice. It runs in the browser at https://aeolookup.com/accountants/taking-on-and-letting-go-of-a-client-accountants-self-check/#tool and asks for no sign-up. ## What each question checks **1. Before writing to a new client's previous accountant, do you get the client's permission, preferably in writing?** The answer that is in order is "yes". Section 320 of ICAEW's code says the incoming accountant needs the client's permission to write, preferably in writing, and the existing accountant needs the client's consent to answer. Without the signed authority the enquiry cannot be answered. 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/). **2. Does your enquiry ask the previous accountant whether a suspicious activity report was ever made about the client?** The answer that is in order is "no". Two questions are off limits in the enquiry under section 320 of ICAEW's code: whether a suspicious activity report has been made, and whether identity checks were carried out. The outgoing accountant must never disclose that a report was made. 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/). **3. Do you start work for a new client while the enquiry to their previous accountant is still unanswered?** The answer that is in order is "no". ICAEW's helpsheet says the new accountant must be satisfied it is proper to act before accepting or starting work. The engagement letter can be drafted meanwhile, and on ICAEW's figures an unanswered enquiry runs to day 42. Source: ICAEW helpsheet for the incoming accountant. The working is in [New client onboarding checklist for accountants](https://aeolookup.com/accountants/new-client-onboarding-checklist-accountants/). **4. For each company client, does the file record who owns and controls the company?** The answer that is in order is "yes". Due diligence on a company includes understanding who owns it. The onboarding file is the evidence a supervisor asks for: identity documents, the beneficial ownership check, the risk rating and the name of the person who approved it. Source: GOV.UK, Your responsibilities under money laundering supervision. The working is in [AML checklist for accountants and bookkeepers](https://aeolookup.com/accountants/aml-checklist-accountants-bookkeepers/). **5. When a client gains a new director or a new line of business, do you look at their due diligence again and date the note?** The answer that is in order is "yes". Due diligence does not end at onboarding. The regulations expect a practice to keep client information current and to look again when something changes, and a dated note on the client file is what shows the monitoring was done. Source: Money Laundering Regulations 2017, regulation 28(11). The working is in [AML checklist for accountants and bookkeepers](https://aeolookup.com/accountants/aml-checklist-accountants-bookkeepers/). **6. Does your engagement letter say who owns which documents and how long the practice keeps them?** The answer that is in order is "yes". ICAEW says records a client gives the practice remain the client's property and recommends the letter deals with ownership. Regulation 40 sets five years after the relationship ends for due diligence records; working papers have no set period. Source: ICAEW guidance on document retention; 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/). **7. Would you hold back a limited company's bank statements and ledgers until its bill is paid?** The answer that is in order is "no". ICAEW's guidance says no lien can be asserted over a company's accounting records as defined in section 386 of the Companies Act 2006. Its helpsheet counts the cash book, ledgers, bank statements, PAYE records and trial balances among them. Source: ICAEW guidance on documents and records; Companies Act 2006, sections 386 and 388. The working is in [Can an accountant keep a client's records until the fees are paid? The four conditions for a lien, and the records you must hand back](https://aeolookup.com/accountants/can-accountant-keep-client-records-unpaid-fees-lien/). **8. If a departing client owes fees, do you wait for payment before answering the new accountant's enquiry?** The answer that is in order is "no". ICAEW's helpsheet says outstanding fees are not a reason for failing to respond to a professional enquiry, though the reply may mention them. The outgoing accountant needs the client's consent to answer, and should then reply promptly. Source: ICAEW helpsheet for the outgoing accountant. The working is in [Disengagement letter template for accountants](https://aeolookup.com/accountants/disengagement-letter-template-accountants/). **9. After you stop acting, do you remove the client from each HMRC online service and from the agent services account?** The answer that is in order is "yes". GOV.UK says an agent removes a client separately for each online service, and from both the agent services account and HMRC online services for agents. Take copies of anything submitted online first: once removed, the practice cannot see that client's data. Source: GOV.UK, Change or remove your authorisations as a tax agent. The working is in [Disengagement letter template for accountants](https://aeolookup.com/accountants/disengagement-letter-template-accountants/). **10. Does the practice verify directors' identities for Companies House without being registered as an authorised agent?** The answer that is in order is "no". A practice can verify clients for Companies House only if it is registered as an authorised corporate service provider, and it must already be under anti-money-laundering supervision. Otherwise each director verifies through GOV.UK One Login, which is free. Source: Companies House identity verification guidance. The working is in [Companies House identity verification](https://aeolookup.com/accountants/companies-house-identity-verification-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.