ACCA welcomes the opportunity to provide feedback on the proposed fees for 2021-2022. We represent ACCA members and firms of accountants registered with the Authority to provide financial services in the Isle of Man (IOM). Our response to this consultation is informed by members’ input obtained from the ACCA Members’ Network in the IOM.
The proposal to increase all fees payable to the Authority over the course of two years, with a 20% increase from 1 April 2021 and a further 20% increase from 1 April 2022, reflects the Authority’s ambition to move towards a predominantly industry-funded model (PIFM) for the IOM financial services sector. While the proposals in the consultation paper do not substantially address this broader issue, they have been developed on the basis that a self-funded structure is desirable.
We note that the Treasury will provide additional resource to the Authority to allow it to protect the Island’s high standards of compliance and regulation in the short term. However, it could be argued that the IOM Government has a vested interest in ensuring that the IOM has a well-regulated and compliant financial services sector and therefore it should continue to bear some responsibility for investing in it over the longer term.
If it is accepted that the IOM financial services sector should fully fund its own regulation, ACCA would be broadly supportive of the proposed flat-rate fee increases for all regulated entities, designated businesses and applicants. While the proposed fee increases are significant in percentage terms, the overall fee increases in Pound Sterling terms appear reasonable and proportionate to the financial position of most firms. We recognise that fee increases represent the first significant change to fee levels in real terms in recent years and the additional funding will enable the Authority to start the transition towards a PIFM. However, we have identified some areas of concern and these are highlighted in our response.
To read the response in full, please download the consultation document in this page.