SAOG15600 | Senior Accounting Officer must provide a certificate to HMRC: how must the SAO provide the certificate

The Senior Accounting Officer (SAO) should provide the certificate to the Commissioners of HMRC. However, we will treat this duty as having been satisfied if it is given to the Customer Compliance Manager (CCM), the Mid-sized Business Customer Engagement Team (CET) or other responsible HMRC officer for the company or companies covered.

The SAO must provide written details in the certificate, see SAOG15200. We will not accept a verbal statement.

CCMs, the CET or other responsible HMRC officer must accept certificates through any recognised paper or electronic format, for example, letter, fax, email, shared workspace (where used).

It is important to verify that an SAO has taken personal responsibility for the completion of their certificate and sending it to HMRC.

Many electronic versions of SAO certificates are scanned copies of paper documents that include the identifiable signature of the SAO. Often those copies of signed certificates are emailed by a third party, such as an agent or secretary, so the SAO’s identifiable signature is HMRC’s assurance of their responsibility for filing that certificate.

However, to reflect the fact that companies increasingly rely on electronic signatures, if an officer of HMRC can validate by the department’s normal email security protocol for external customers that an SAO personally sent an e-mail containing a company’s certificate, that certificate can be accepted if it contains all the information detailed at SAOG15200.

If an emailed SAO certificate does not include the SAO’s identifiable signature, or it cannot be verified that the SAO emailed it personally, it should not be accepted.

FA09/SCH46/PARA2 (3)(a)