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Guide · Internal
The Failure to Prevent Fraud Offence for Accounting Firms
The defence is written procedures. Here is what a practice needs to have in place and be able to show.
Built by a practising Chartered Accountant · Unlimited users · 60-day free trial · Last updated 27 September 2026
Quick answer
The failure to prevent fraud offence can make an in-scope organisation liable where an associated person commits fraud intending to benefit it. The defence is having reasonable fraud prevention procedures. For practices that means a written risk assessment, clear policies, training records and monitoring you can evidence.
Which firms are in scope?
Scope is based on organisation size criteria set out in the legislation and guidance, so many smaller practices fall outside it — but client companies may be inside.
Check the size thresholds carefully for your own firm and consider whether corporate clients are in scope, because they will look to their accountant for help. Take advice where the position is unclear.
What are reasonable prevention procedures?
A documented, risk-based framework: a fraud risk assessment, proportionate policies, training, reporting routes, due diligence and monitoring.
The parallel with AML procedures is close, and much of the evidence overlaps. Keep the fraud risk assessment separate and dated, keep training records, and review both annually as a scheduled job rather than when someone remembers.
The Failure to Prevent Fraud Offence for Accounting Firms: step by step
- 1
Check your scope
Assess whether your firm meets the size criteria.
- 2
Run a fraud risk assessment
Document where fraud risk arises in your services and clients.
- 3
Write proportionate policies
Set out what is prohibited and what staff must do.
- 4
Train and record
Deliver training and keep dated records of it.
- 5
Create reporting routes
Give staff a clear internal way to raise concerns.
- 6
Monitor and review
Schedule an annual review of the risk assessment and policies.
See it working with your own clients
A 30-minute walkthrough using your services, deadlines and templates.
How do you do it in Remindoo?
- Store the framework. Keep the risk assessment and policies where the team can find them.
- Schedule annual reviews. Create recurring jobs for the policy and risk assessment review.
- Record training. Track training completion per staff member.
- Use role permissions. Limit who can change sensitive client and financial data.
- Keep AML evidence together. Hold risk assessments, ID checks and monitoring on the client record.
- Evidence the monitoring. Use task history to show reviews actually happened.
AML risk scoring and digital ID checks
Risk assessments plus built-in digital KYC, AML and proof-of-address checks.
See featureRecurring tasks
Repeat work is created automatically on schedule.
See featureRoles and permissions
Control who sees and edits client data.
See featureAdvanced employee roles (Growth plan)
Give employees role-based access suited to their responsibilities.
See featureCentralised client information
Services, documents and notes in one record.
See featureWhat are the common mistakes?
- Assuming the firm is out of scope without checking
- Policies written but never communicated
- No dated training records
- No monitoring evidence
- Never reviewing the fraud risk assessment
“Automated reminders and task templates save countless hours each week.”
Frequently asked questions
Does this offence apply to small practices?
Scope depends on size criteria in the legislation and guidance. Check your position and take advice if it is borderline.
What is the defence?
Having reasonable fraud prevention procedures in place. Documentation, training and monitoring are central to demonstrating it.
Is this the same as AML compliance?
No, but the framework looks similar and much of the evidence — risk assessment, training, monitoring — follows the same pattern.
Should client companies be advised about it?
Many in-scope corporate clients will need procedures of their own, which is a genuine advisory opportunity.
How often should procedures be reviewed?
At least annually, and after any significant change in services, clients or structure.
How does Remindoo help?
It stores the policies and records, schedules the annual reviews as jobs, restricts access by role, and keeps AML and due diligence evidence on the client record.
Ready to run a calmer practice?
See Remindoo with your own clients, or start free for 60 days with unlimited users.
Sources
Last updated 27 September 2026. General guidance, not regulatory advice.
Why recording every task matters in an accountancy practice
Accounting firms run on deadlines: VAT returns, payroll, confirmation statements, accounts and Self Assessment. Recording every job as a task, with an owner and a date, is the simplest way to make sure nothing is missed.
Avoid penalties
HMRC and Companies House charge penalties for late filing. A task for every deadline, with an internal date before it, gives the team a buffer.
Nothing depends on memory
Recorded tasks mean work continues when someone is off sick, on leave or has left the firm.
Consistent quality
Subtask checklists make every job follow the same steps and reviews, whoever does the work.
Visibility for managers
Filters by owner, status and deadline show at a glance what is late, what is due and who needs help.
Practical tips from UK practice
- Set an internal deadline two to four weeks before every statutory deadline.
- Use recurring tasks for repeat work such as VAT, payroll and bookkeeping.
- Break larger jobs into subtasks, including a review step.
- Comment on the task instead of by email, so the history stays with the work.
Related Remindoo features
Written and reviewed by Waqas Sagar ACA FCCA FMAAT, Chartered Accountant with 18+ years in practice. Founder and MD of Accotax, an ICAEW, ACCA and AAT regulated London practice that has served over 5,000 clients, and founder of Remindoo. Guidance is general; check current GOV.UK and professional body guidance for your firm.
What UK practices say about Remindoo
Read all reviews on Trustpilot“With Remindoo, everything from the first enquiry to onboarding and ongoing client management is tracked in one place… It saves us hours and gives me, as a practice owner, complete visibility of where the firm stands.”
“The biggest benefit is having clients, tasks, deadlines, workflows, proposals and communication all organised in one place.”
“During my trial, the team were absolutely amazing. They helped onboard my clients, set up my settings and made sure everything was ready for me to use… they made the whole process completely stress-free.”
“It brings client information, tasks, recurring deadlines, workflows and reminders together in one place, giving us much better visibility across the team.”
