Non-ICAEW accountants: which body’s PI rules apply to you?

Reviewed by the Apex broking team · Last reviewed 2026-08-22 · Position stated as at August 2026

Start here: which route are you on?

• ICAEW member or ICAEW-regulated firm → the ICAEW Professional Indemnity Insurance Regulations apply.
• ACCA practising certificate, insolvency licence or firm’s auditing certificate → the ACCA Professional Indemnity Insurance Regulations apply.
• AAT licensed member → AAT’s licensing requirements apply.
• CIMA member in practice → CIMA’s Member in Practice rules apply.
• No professional body → no regulatory minimum applies to you at all. Your cover is driven by client contracts, lenders, and your own risk appetite.

Two cautions before you read on. First, statutory audit, insolvency, investment business, probate and other reserved activities carry their own additional requirements on top of the general PI rules. Second, if you hold more than one qualification, the stricter regime is the safe assumption.

ICAEW — the benchmark everyone else is measured against

The ICAEW Professional Indemnity Insurance Regulations effective from 1 September 2024 are the reference point most brokers and most clients use, even for firms that are not ICAEW-regulated.

• Minimum limit: regulation 3.2 requires at least £2 million for any single claim and in the aggregate, except where regulations 3.3, 3.4, 3.5 or 3.8 apply.
• Smaller firms: regulation 3.3 provides that where gross fee income is less than £800,000, the minimum limit is two and a half times gross fee income, subject to a floor of £250,000.
• Qualifying insurance: cover must be with a participating insurer and the policy terms must accord with ICAEW’s approved minimum wording.
• Run-off: mandatory. A member ceasing public practice must take reasonable steps to remain covered for at least two years (regulation 2.7); when a firm ceases, the members must ensure cover for two years and then take all reasonable steps to secure a further four.

We cover the ICAEW route in detail on the ICAEW Bye-law 61 and PII Regulations guide.

ACCA — a banded formula, not a flat limit

ACCA’s Professional Indemnity Insurance requirements apply to all holders of practising certificates, insolvency licences, firms’ auditing certificates and firms’ investment business certificates (Ireland). The minimum limit is calculated by band:

• Total income up to £200,000: the greatest of 2.5 times total income, 25 times the largest fee raised in the previous accounting year, or £50,000.
• Total income £200,001 to £700,000: the greater of the aggregate of £300,000 plus the firm’s total income, or 25 times the largest fee raised.
• Total income over £700,000: the greater of £1 million or 25 times the largest fee raised.
• Excess: the maximum permitted uninsured excess is the lower of £20,000 per principal and 2% of the level of indemnity, for each and every claim.
• Run-off: six years from the date of cessation.

The “25 times the largest fee” test catches out small firms with one large client. A consultancy-heavy practice with modest total income and a single substantial engagement can be required to carry a limit far above the headline band. See ACCA PI requirements explained and the ACCA versus ICAEW comparison.

AAT — mandatory for licensed members, capped at the top

AAT states that professional indemnity insurance is a mandatory requirement for all AAT licensed members. The minimum level depends on how the practice is structured:

• Sole traders: the greater of 2.5 times the firm’s gross fee income or £50,000.
• Partnerships and limited companies: the greater of 2.5 times gross fee income or £100,000.
• Cap: where gross fee income exceeds £400,000, the maximum cover AAT requires is £1,000,000.
• Excess: members are told to set the self-insured excess at an amount they are able to meet at all times.
• After ceasing: AAT advises maintaining cover for a minimum of six years after ceasing to trade as a licensed member, because the policy is claims-made.

Note the shape of the AAT rule: it is generous at the bottom and capped at the top. A larger AAT practice can satisfy its licensing requirement and still be carrying a limit that a single client dispute would exhaust.

CIMA — what we will and will not state

CIMA operates a Members in Practice regime with its own mandatory requirements, and applicants for a practising certificate must satisfy CIMA that they meet the eligibility criteria set out in CIMA’s Member in Practice Rules.

We have not been able to confirm CIMA’s current minimum limit of indemnity, excess cap or run-off period from CIMA’s own published rules, so this page does not state one. If you are a CIMA member in practice, take the figure from CIMA’s Member in Practice Rules directly and give your broker the wording, not a summary of it.

No professional body — the unregulated route

If you provide bookkeeping, management accounts, payroll or tax services without holding a practising certificate from any body, no regulatory minimum applies to you. That does not mean the exposure is smaller. It means nobody is setting the limit for you.

In that position the sensible reference points are the contracts you sign, the size of the largest engagement you handle, and what a claim would cost to defend rather than to pay. Many unregulated practices adopt the ICAEW or ACCA formula voluntarily, simply because it is a defensible basis for choosing a number.

Two things still bite regardless of professional body: anti-money-laundering supervision, and the fact that an unregulated practice is no less capable of causing loss than a regulated one. Neither is an insurance question, but both belong in the same conversation.

How to use this once you know your route

• Take the regulator’s minimum as a floor, never a target. Every body above describes its figure as a minimum.
• Size the limit against your largest engagement and your worst realistic claim, not your fee income.
• Check the excess rules separately — ACCA caps it, AAT frames it as affordability, and an excess you cannot fund is a coverage problem in disguise.
• Deal with run-off before you need it. Every route above assumes claims will arrive after the work, and sometimes after the firm.

See also

• Accountants PI insurance guide — the sector pillar for accountants
• ICAEW vs ACCA vs AAT — the requirements side by side
• Sizing a limit above the minimum — how to choose the number
• Do I need PI insurance as an accountant? — the threshold question

References

• ICAEW Professional Indemnity Insurance Regulations, effective from 1 September 2024, regulations 2.7, 2.8, 3.2, 3.3, 3.6 and 3.7
• ACCA Professional Indemnity Insurance requirements (ACCA, published guidance for practising certificate holders)
• AAT professional indemnity insurance requirements for AAT licensed members

Frequently asked questions

I am not an ICAEW member. Do the ICAEW PII Regulations apply to me?

No. The ICAEW Professional Indemnity Insurance Regulations apply to ICAEW members and firms that ICAEW regulates or licenses. If you are an ACCA or AAT practitioner, your own body's rules apply instead. The ICAEW figures are still widely used as an informal benchmark by clients and brokers.

Which body's rules apply if I hold more than one qualification?

Assume the stricter one. If you hold a practising certificate from more than one body, or your firm is regulated by one body while an individual is a member of another, more than one set of requirements can apply at the same time. The safe course is to satisfy the highest limit, the lowest permitted excess and the longest run-off period across all of them.

What if I am not a member of any professional body at all?

Then no regulatory minimum applies to you. Your professional indemnity limit is set by whatever your client contracts require and by your own assessment of the exposure. Many unregulated practices adopt the ICAEW or ACCA calculation voluntarily as a defensible starting point.

Why does this page not give a figure for CIMA?

Because we could not confirm CIMA's current minimum limit, excess cap or run-off period from CIMA's own published Member in Practice Rules. We would rather leave a gap than publish a number that turns out to be out of date. CIMA members in practice should take the requirement from CIMA directly.

This page is insurance information for UK businesses, not legal advice. It is a general summary and cannot take account of your own facts, your policy wording or your regulator’s current rules; take advice before acting on it. Position stated as at August 2026.

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority (FRN 724952). This page is general information, not advice on a specific policy.