Three of the UK's main accountancy bodies — the Institute of Chartered Accountants in England and Wales (ICAEW), the Association of Chartered Certified Accountants (ACCA) and the Association of Accounting Technicians (AAT) — each require their practising members to hold professional indemnity (PI) insurance. The headline rules look similar at a glance: each body links the minimum cover to fee income, each requires civil liability cover, each sets a position on run-off. Read the rule books carefully and the differences become significant.
This guide compares the PI requirements of ICAEW, ACCA and AAT for practising members in the UK, as understood at the time of writing in May 2026. Figures are taken from publicly available rule books and guidance published by each body at that date. Each body reviews its PI requirements periodically, so practitioners should always check the current position with the relevant body before relying on these figures for compliance purposes.
What this comparison covers
This article compares the PI requirements for accountants regulated by:
- ICAEW, through the ICAEW Professional Indemnity Insurance Regulations.
- ACCA, through the ACCA Global Practising Regulations and the Rulebook.
- AAT, through the AAT Licensed Member regulations.
It does not address audit-specific requirements set by the Financial Reporting Council (FRC) or the audit registration provisions, nor the additional rules that apply where a firm is also regulated for insolvency, probate, investment business or other reserved activities. Every figure quoted reflects publicly available rule books and guidance as of May 2026 — please verify with the relevant body before treating any figure as current.
Why the bodies set different requirements
ICAEW, ACCA and AAT each authorise members to provide accountancy services to the public, but the populations they regulate differ. ICAEW practising members typically lead audit, assurance, tax and advisory firms, often with sophisticated corporate clients. ACCA practising members cover a similarly broad spectrum, with significant numbers operating internationally. AAT licensed members include bookkeepers, tax agents and accountancy technicians, many serving smaller businesses and individuals.
The PI rules each body sets reflect the practice profiles of its members. The fee-income multiplier model is common because it scales cover with the volume of work being delivered, while a floor (a minimum absolute figure) prevents very small practices from sitting underinsured. The differences in the multipliers, floors and caps reflect different views about appropriate cover at the boundary of practice size and risk.
Each body's framework is set in the context of its statutory and constitutional position. None of this is to suggest one regime is better calibrated than another — they are set for different member populations and reviewed periodically by each body in line with its governance.
Body 1: ICAEW
Who it applies to
The ICAEW PI Regulations apply to all ICAEW members holding a practising certificate and to firms regulated by ICAEW that provide services to the public. Members in employment within non-public-facing roles are not required to hold their own PI by virtue of the ICAEW Regulations, though their employer may carry cover.
Minimum cover position
ICAEW's PI Regulations require firms to hold cover at a minimum of 2.5 times gross fee income, subject to a floor and a cap. As understood at the time of writing in May 2026, the floor sits at GBP 100,000 in the limit for any one claim and the cap for the regulatory minimum sits at GBP 1.5 million for firms with gross fee income above the corresponding threshold. Practitioners with very low fee income are still required to hold the floor.
The 2.5x multiplier produces a sliding scale: a firm with GBP 200,000 of gross fee income must hold at least GBP 500,000 of cover, while a firm with GBP 500,000 of fee income must hold at least GBP 1.25 million.
Aggregation rules
ICAEW's PI Regulations require cover on a "each and every claim" basis up to the regulatory minimum — that is, the minimum sum insured must be available for each claim rather than aggregated across the period. Some excess layers placed above the minimum may aggregate, but the regulatory floor cannot.
Run-off requirements
ICAEW requires firms ceasing practice to arrange run-off cover for a minimum of two years, with strong recommendation to extend cover beyond that period given the long-tail nature of accountancy claims. Many firms purchase six years or more of run-off in line with statutory limitation periods.
Wording requirements
The cover must be written on a civil-liability basis. ICAEW maintains a list of participating insurers that have agreed to write cover meeting ICAEW's PI Regulations, although ICAEW members are permitted to place cover with non-participating insurers provided the cover meets the Regulations. Defence costs must be addressed and the policy must respond appropriately to claims arising from past acts.
Critical compliance points
ICAEW firms must complete an annual return confirming PI compliance. Failure to hold compliant cover is a regulatory matter that can lead to disciplinary action.
Body 2: ACCA
Who it applies to
The ACCA Global Practising Regulations apply to ACCA members holding a practising certificate in the UK and to ACCA-authorised firms providing public-facing services in the UK. The rules apply to members in practice — those in employment within non-practising roles are not subject to the practising-certificate PI requirements.
Minimum cover position
ACCA's PI requirements, as understood at the time of writing in May 2026, also use the 2.5x gross fee income model with a floor and a cap. The floor sits at a level set in the ACCA Rulebook and the cap sits at a level proportionate to the size of practice ACCA regulates in the UK. Practitioners should refer to the current Rulebook, which is updated periodically, for the exact figures applicable in the current period.
For most small and medium ACCA-authorised firms in the UK, the practical effect of the 2.5x rule is similar to ICAEW's: cover scales with fee income, subject to a sensible floor for very small practices.
Aggregation rules
ACCA requires cover that responds to each claim up to the minimum required, on a civil liability basis. The specific aggregation position depends on the wording placed in the open market, and ACCA's guidance asks firms to consider whether the cover is sufficient given the firm's claims experience and exposure profile.
Run-off requirements
ACCA requires run-off cover for at least two years after cessation of practice in the UK, with guidance recommending longer cover where the firm's exposure profile warrants it.
Wording requirements
ACCA does not operate a participating-insurer list in the same prescriptive form as some other regulators. Members are required to satisfy themselves that the policy wording meets the Rulebook requirements, including civil liability cover, claims-made operation and appropriate defence costs treatment.
Critical compliance points
ACCA practising members must confirm PI cover as part of their annual return. ACCA may request evidence of cover, particularly in response to a complaint or regulatory query.
Body 3: AAT
Who it applies to
AAT regulates licensed members in practice — typically bookkeepers, tax agents and accountancy technicians providing services to the public under an AAT licence. The PI requirements apply to AAT licensed members in practice, not to AAT members in employment.
Minimum cover position
AAT's PI requirements for licensed members in practice operate on a similar fee-income model. As understood at the time of writing in May 2026, AAT licensed members are required to hold cover of at least 2.5 times annual gross fee income, with a minimum floor of GBP 25,000 in the limit for any one claim. The floor is lower than the ICAEW and ACCA floors, reflecting the typical practice scale of AAT licensed members.
For an AAT licensed bookkeeper turning over GBP 30,000 a year, the 2.5x rule produces a minimum cover of GBP 75,000. For an AAT licensed practice with GBP 100,000 of fee income, the minimum sits at GBP 250,000.
Aggregation rules
AAT requires the cover to respond on an each-claim basis up to the minimum. The aggregation position above the minimum follows the market wording.
Run-off requirements
AAT requires licensed members to make arrangements for run-off cover on ceasing practice. The duration set in AAT's guidance reflects the limitation periods applicable to typical bookkeeping and tax-agent work.
Wording requirements
The cover must be on a civil-liability basis and must address claims-made operation, defence costs and run-off. AAT does not operate a participating-insurer list. Members place cover in the open market.
Critical compliance points
AAT licensed members confirm PI cover at annual licence renewal and must notify AAT if cover lapses or materially changes.
Comparison table
| Body | Minimum sum insured | Floor | Cap on regulatory minimum | Aggregation | Run-off | Participating-insurer list | Notes | |---|---|---|---|---|---|---|---| | ICAEW | 2.5x gross fee income | GBP 100,000 | GBP 1.5m for larger firms | Each-and-every for minimum layer | Minimum 2 years (longer recommended) | Yes (optional to use) | Annual return; civil liability basis | | ACCA | 2.5x gross fee income | Per ACCA Rulebook | Per ACCA Rulebook | Each-claim for minimum layer | Minimum 2 years (longer recommended) | No formal list | Civil liability basis | | AAT | 2.5x gross fee income | GBP 25,000 | Per AAT licensed member rules | Each-claim for minimum layer | Required on cessation | No formal list | Tailored to typical AAT practice scale |
All figures above reflect the rule books and published positions of each body as understood at the time of writing in May 2026. Each body updates its position from time to time, and practitioners should confirm directly with the body before relying on these figures.
Where the requirements overlap and diverge
The three bodies share a common architecture: a fee-income multiplier, a floor, a cap or scaled cap, civil liability cover, run-off on cessation, and an expectation that cover responds on an each-claim basis up to the regulatory minimum. The underlying approach — calibrate cover to the size of practice and provide a backstop floor — is consistent.
The divergence is in the calibration. ICAEW's floor and cap reflect a member population that typically includes larger and more complex firms. AAT's floor and the lower end of its band reflect a member population that often consists of sole-trader bookkeepers and small tax-agent practices. ACCA sits between the two, with rules calibrated for a broad mixture of practice sizes in the UK and internationally. None of these positions is better than another in absolute terms — they are calibrated for their respective member populations.
A further divergence is in the participating-insurer arrangement. ICAEW historically operates a participating-insurer list, while ACCA and AAT typically rely on members placing compliant cover in the open market without a formal list. The practical effect is that ICAEW members can use the participating-insurer route as a confidence signal, while ACCA and AAT members need to take a slightly more active role in confirming wording compliance.
When you may be regulated by more than one body
It is common for accountancy firms to have members of more than one body on the team. A partner might be ICAEW, a senior manager ACCA and a bookkeeper AAT licensed. In a firm-regulated structure, the firm's PI cover typically needs to satisfy the most demanding of the applicable rules. A firm regulated by ICAEW must place cover meeting ICAEW's regulations; if there are ACCA practising members or AAT licensed members within the firm, the same cover will usually satisfy their bodies' requirements as well, provided the wording meets each body's specific points.
Other multi-body situations include:
- An accountant who is also a Chartered Tax Adviser (CIOT/ATT) — CTA practising members are subject to CIOT's own PI requirements, which the firm's cover must also satisfy.
- An accountant who is also an Insolvency Practitioner — additional requirements apply through the recognised professional body for insolvency.
- An accountant who is also a probate practitioner authorised by ICAEW — the firm's cover must satisfy the probate authorisation requirements as well.
The general principle is straightforward: where multiple bodies apply, the cover must satisfy the most demanding rules among them.
Voluntary cover above the minimum
Many accountancy firms carry cover well above the regulatory minimum. Common drivers include:
- Commercial clients requiring evidence of cover at a level higher than the firm's regulatory minimum — GBP 5 million is a frequent expectation for clients of larger SMEs and corporate groups.
- Audit and assurance work, which carries different and often larger exposures than core compliance accountancy.
- Tax advisory work, where a single advice can produce a claim multiple times the original fee.
- Specialist advisory work — corporate finance, valuations, due diligence, expert witness — which carries larger potential exposures.
- M&A activity in the client base, where errors can produce claims with multi-million pound consequences.
Many SME accountancy firms carry GBP 1 million to GBP 5 million of cover even where the regulatory minimum would permit less. Larger firms typically carry significantly more. The minimum is a regulatory floor, not a market norm or a risk-management ceiling.
What to ask your broker (or directly to the insurer)
1. What is the policy limit and is it on an each-and-every-claim basis up to the regulatory minimum? 2. How does the policy respond to fee-income changes during the year — is the cover indexed or fixed? 3. Are defence costs inside or outside the limit? 4. What is the position on retrospective cover for past acts and on changes of insurer? 5. What run-off provision is offered, and at what cost, on cessation of practice? 6. How does the policy treat claims arising from audit, tax advisory, probate, insolvency or other regulated activities? 7. Does the policy address contingent liabilities arising from outsourced services (cloud bookkeeping, payroll bureaux, etc.)? 8. Is the insurer on the ICAEW participating-insurer list (where ICAEW membership applies)?
How a broker helps in body-regulated PI placements
PI for accountants is a specialised market segment. A broker familiar with the ICAEW PI Regulations, the ACCA Rulebook and the AAT licensed-member regime can help firms place cover that meets each applicable body's requirements, manage renewal timing and respond to changes in fee income or activity profile. Brokers also help firms with claims notifications and circumstances reporting, which are increasingly important given the long-tail nature of accountancy claims.
Apex Insurance Brokers Limited places PI for firms regulated by ICAEW, ACCA and AAT. We do not suggest that a broker is the only sensible route — firms can also approach insurers directly or use other channels. The point is that PI for accountants is rarely a commodity and the wording can have meaningful consequences in the event of a claim.
FAQ
Do all three bodies use the same fee-income multiplier?
Yes — at the time of writing in May 2026, ICAEW, ACCA and AAT all use a 2.5x gross fee income model for setting the minimum sum insured. The differences are in the floor and cap figures and in the wording requirements.
What is the floor for AAT licensed members in practice?
As understood at the time of writing in May 2026, AAT requires a minimum sum insured of GBP 25,000 or 2.5x gross fee income, whichever is the higher. Practitioners should check the current AAT licensed-member regulations for the position applicable to their licence period.
Does ACCA operate a participating-insurer list?
ACCA does not operate a participating-insurer list in the same prescriptive form as some other regulators. Members are required to ensure that the cover placed meets the ACCA Rulebook requirements.
If a firm has ICAEW, ACCA and AAT members all on the team, which rules apply?
In a firm-regulated structure, the cover must satisfy the most demanding of the applicable rules. In practice, an ICAEW-compliant policy will usually satisfy ACCA and AAT requirements as well, but the wording should be checked against each body's specific points.
Are the regulatory minimums the same as the market norms?
No. The regulatory minimums are floors set by each body. Many firms carry cover well above the minimum to satisfy client expectations, to reflect the risk of specific service lines (such as tax advisory or audit work), or to protect themselves against larger claims.
How long should run-off cover last?
Each body sets a minimum, but accountancy claims have a long tail and many firms purchase six years of run-off in line with statutory limitation periods. The right duration depends on the firm's exposure profile and on whether successor arrangements are in place.
Is audit work covered by standard accountants' PI?
Standard accountants' PI typically covers audit work, but the cover may be subject to specific terms reflecting the higher exposure profile of audit. Firms holding audit registration should confirm that the policy responds appropriately to audit claims.
Are these requirements likely to change?
Each body reviews its PI requirements periodically. The figures and structures in this article reflect publicly available rule books as of May 2026. Always check the current position with the relevant body before relying on these figures.
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Related guides
- Professional Indemnity Insurance overview
- Does my professional body require PI insurance?
- Accountants Professional Indemnity Insurance
- Contact Apex Insurance Brokers
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About Apex Insurance Brokers — Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority, FCA firm reference 724952. Registered in England and Wales, Companies House 07014570. Last reviewed: May 2026.
Note on figures: regulator-set minimums and policy wording requirements are updated periodically by each body. The figures in this guide reflect our understanding as of writing in May 2026. Always confirm current requirements with the relevant regulator or professional body before relying on them for compliance purposes.