CAA/ATOL reporting

ACCA and the Civil Aviation Authority (CAA) have signed a memorandum of understanding that sets out obligations on ACCA members, ACCA and the CAA that will apply from April 2016.

Members wishing to undertake CAA and ATOL reporting work are required to register with, and have a licence issued by, ACCA.  

ACCA has decided that this licence will not require an additional fee for members. Non-members will be required to pay a fee when registering. 

In addition, members must register and complete the training required by CAA/ATOL prior to the granting of the licence. 

To undertake these, members should register with the CAA

The following information will be required from each accountant by CAA:


Professional accountancy body 

Member registration number 

Email address 


Registration with and licensing by ACCA is free of charge to ACCA members and is open to members who:

  • hold an ACCA Practicing Certificate
  • have taken and passed a professional examination covering assurance work as approved by the CAA. For ACCA members this is F8 Audit and Assurance or P7 Advanced Audit and Assurance or previous equivalents

Agreement and requirements

The agreement between ACCA and CAA states that ‘ACCA will designate and regulate ARA firms and ARAs in accordance with the provisions within the ACCA Rulebook and in full compliance with the requirements of the CAA’s ARA Scheme Key Components document and which forms part of this agreement’.

Some of the basic requirements of the Key Components document are that: 

  • each principal in the firm should be subject to disciplinary arrangements 
  • there should be at least one designated ATOL reporting accountant for the relevant category of registered ATOL work.

The firm must demonstrate that:

  • it has PII that is at least sufficient to cover the liability cap in the CAA Guidance Note 10 (the current liability cap ranges from £250,000 to £20,000,000)  
  • the principal business of the firm is the provision of accountancy services
  • it is independent of the ATOL holder
  • it has appointed a contact principal.

The reporting accountant is also expected to demonstrate competence and must:

  • have reviewed guidance (including but not limited to Guidance Note 10 - Advice for Accountants) issued by CAA ATOL and their professional body for ATOL reporting accountants
  • have successfully completed the CAA ATOL training package (as updated from time to time) and the training package and assessment has been shared with the professional bodies within this arrangement
  • have taken and passed a professional examination covering assurance work as approved by the CAA (this may be limited to individual modules of a professional qualification but must include an assurance qualification)
  • be a member of an approved professional body, as determined by CAA, and hold a practising certificate where required by the professional body.

The individual designated ATOL Reporting Accountant must be independent of the ATOL holder.

Other requirements

Other requirements include:


A firm must 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. 

The individual must also meet the continuing professional development guidelines of its professional body for the purposes of ATOL reporting. 

Manuals and programmes 

A firm must maintain an appropriate level of competence in the conduct of ATOL work and this is best achieved through the use of relevant and bespoke manuals, programmes, checklists and procedures so that the firm has a body of knowledge. Such documentation must be kept up to date if the firm is to retain its competence.

Liability of firm/designated ATOL reporting accountant to disciplinary action 

The professional body will determine whether a firm/designated ATOL reporting accountant is liable to disciplinary action under the professional body’s disciplinary arrangements if:

  • it has performed its ATOL reporting work inefficiently or incompetently to such an extent as to bring discredit on itself/him/herself, or
  • if it has breached any of the provisions of the registration arrangement.

Approved professional body monitoring

A firm must appoint a contact principal who will supply the professional body with information as required and provide an annual declaration to the professional body of the individual designated ATOL reporting accountant compliance with its responsibilities under the registration arrangement rules. 

The professional body will use the information and annual declaration in their assessment of the continuing designation of the accountant as an ATOL reporting accountant.

Conduct of licensed work 

A designated ATOL reporting accountant must:

  • act in accordance with the International Ethics Standards Board for Accountants Code of Ethics for Professional Accountants and 
  • comply with any additional conduct of business requirements that are set out in the registration arrangement rules of the professional body for an application to become a designated ATOL reporting accountant. 

CAA guidance

A designated ATOL reporting accountant should follow Guidance Note 10 when performing ATOL returns/reporting work. 

Under the ARA scheme, the firm should take responsibility for firm-wide elements including:

  • policies and procedures
  • work programmes
  • internal compliance reviews
  • firm-wide training
  • fit and proper declarations.

The individual designated ATOL reporting accountant will sign off ATOL reports. 

ACCA licence forms

The forms are currently being produced and will be available from ACCA.

More information

Download ACCA's technical factsheet, ATOL reporting to the Civil Aviation Authority