ACCA’s PI rules are simpler than ICAEW’s on paper and harder to satisfy in practice.
Every ACCA member holding a practising certificate is required to maintain professional indemnity insurance that meets the standard set out in the ACCA Global Practising Regulations. The headline calculation — 2.5 times gross fee income, subject to a cap — looks identical to ICAEW’s, and many practitioners assume the two regimes are interchangeable. They are not. The detail on excess, on participating insurer status, on run-off and on the practising-certificate condition all differ, and the differences matter when a claim is in play or a firm is approaching renewal. This guide sets out the ACCA position and where it diverges from the ICAEW regime.
The ACCA Global Practising Regulations require any member or firm holding a practising certificate to maintain PI cover from the date the certificate is granted and at every renewal. The certificate is not issued, and will not be renewed, without confirmation that compliant cover is in force. ACCA audits this annually through the practising certificate renewal process.
The minimum limit is calculated as 2.5 times gross fee income for the preceding accounting year, subject to a regulatory cap and a floor. The floor sits at £100,000 for the smallest practices; the cap currently sits at £1.5 million for the calculated limit before any uplift. Firms with gross fee income above £600,000 will, on the 2.5x calculation, exceed the £1.5 million figure — at that point the cap engages and the regulatory minimum is £1.5 million, although ACCA expects firms to consider whether a higher commercial limit is appropriate given the risk profile of the work being done.
Where ACCA differs most clearly from ICAEW in commercial practice is around excess levels and the practising-certificate-holder condition. ACCA imposes a maximum permitted excess scaled to fee income — typically 2% of gross fee income or £20,000, whichever is lower, with a hard upper limit beyond which the policy is treated as non-compliant. ICAEW’s regime has historically been more flexible on excess for larger firms. We have seen ACCA-regulated practitioners renew with an excess set at insurer-suggested levels only to discover it puts them in breach of the practising-certificate condition.
The practising-certificate condition itself is the other watch-point. The certificate is granted to the individual, not the firm. A sole practitioner who lets cover lapse is in breach personally; a member working within a multi-partner firm relies on the firm’s policy to keep the certificate alive. If the firm policy is cancelled mid-term — for non-payment, non-disclosure, or any other reason — every certificate-holder in the firm is technically in breach of ACCA rules from the cancellation date.
For a broader treatment of the ICAEW position and a comparison across the two regimes, see our ICAEW PII regulations explained and the buyer’s overview in PI insurance for accountants.
ACCA does not maintain a “participating insurer” list in the formal sense that ICAEW does. Instead, the Global Practising Regulations specify the criteria a compliant policy must meet: claims-made trigger, civil liability wording (not narrow “negligence only” wording), retroactive cover back to first commencement of regulated practice, defence costs in addition to limit where commercially available, and a clear statement that the policy responds to all professional services rendered to clients in the member’s capacity as a practising accountant.
The Insurance Act 2015 governs the contract itself once the policy is in force. The duty of fair presentation under section 3 applies to every ACCA-regulated firm at inception and at every renewal — and contracting-out provisions under section 16 are commercially relevant where insurers seek to impose stricter disclosure obligations than the Act’s defaults. The remedies for breach under section 8 (proportionate response) and the relief under section 11 (terms not relevant to actual loss) are points we routinely raise on coverage disputes for ACCA-regulated clients.
For run-off, the ACCA regulations require continuous cover for a minimum period — two years from cessation at the same limit and on the same basis as the trading policy — with an obligation to notify ACCA of any cessation, sale or merger. The practical run-off question is treated in more detail in accountants run-off cover.
Where ACCA-regulated firms also undertake regulated work outside the scope of pure accountancy — investment business under the DPB licence, insolvency, ATOL reporting, probate — additional PI requirements may apply through the relevant regulator. ACCA-licensed insolvency practitioners must also meet the bonding requirements of the Joint Insolvency Committee, which sit alongside, not within, the PI policy.
A two-director ACCA-regulated limited company in London turns over £480,000 in gross fee income for the year to March 2025. Applying the 2.5x calculation: minimum limit required is £1,200,000. The cap does not engage. The firm’s insurer offers a £1,500,000 limit with a £15,000 excess for an annual premium of around £6,500.
At renewal, the broker suggests increasing the excess to £40,000 to reduce premium by approximately £1,200. The directors agree. Six months later, a former client brings a claim alleging negligent corporation tax advice; defence costs alone are £30,000 by the time of the first response. The firm tenders the excess. The insurer accepts cover but ACCA, conducting a routine practising-certificate review, identifies the £40,000 excess as exceeding the regulatory cap. Both directors are referred to the ACCA disciplinary process for non-compliance with the Global Practising Regulations.
The substantive claim is handled in the normal way. The regulatory breach is separate. The disciplinary outcome is a reprimand and a fine — modest in itself, but reportable on every future PI proposal form and on every tender response for years afterwards. The £1,200 premium saving was the most expensive £1,200 the firm spent that year.
Apex’s view: The ACCA excess cap is the single most overlooked compliance point we see. Brokers selling on price will recommend a higher excess to shave premium, and the practitioner agrees because the saving is visible and the rule is not. We treat the ACCA excess limit as a hard line at quoting stage, not a suggestion to be balanced against budget. If a firm cannot afford the premium at a compliant excess, the answer is to reduce the limit (where the calculation allows) or shop the market, not to take a non-compliant excess. The disciplinary consequences sit on the file for years; the premium saving lasts twelve months.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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