ACCA PII vs ICAEW: two accountants regimes compared

~4 min read

Reviewed by Matthew Bartlett, Director · Last reviewed 2026-07-06

Two of the UK's largest chartered accountancy bodies — the Association of Chartered Certified Accountants (ACCA) and the Institute of Chartered Accountants in England and Wales (ICAEW) — regulate their members' professional indemnity insurance under separate rulebooks. Members carrying only ACCA credentials follow ACCA's Global Practising Regulations and the ACCA UK-specific Practising Regulations. Members carrying ICAEW credentials follow Bye-law 61 and the PII Regulations made by the ICAEW Council. Firms with a mix of ACCA and ICAEW members — or members holding both credentials — need to satisfy both regimes. The two regimes converge on the broad shape of what PII cover must look like but diverge on the detail. This entry compares them side by side.

The compulsory limit

The ICAEW Regulations require the greater of £1.5 million or 2.5 times gross fee income. The ACCA Practising Regulations require a limit calibrated to fee income on a similar scaling principle but expressed in different bands, with a floor at £100,000 for very small practices and a scaling multiplier that rises through fee-income tiers. The upper reaches of the ACCA scale operate broadly comparably to the ICAEW 2.5× figure for firms of similar size, but at the smaller end the two regimes can produce meaningfully different minimums. A sole practitioner with £80,000 of fees would carry £1.5m under ICAEW and a materially lower minimum under ACCA. A £2 million practice would produce broadly similar minimums under the two regimes.

Where a firm has members from both bodies, the operative minimum for the firm is the higher of the two calculations. That is not a formal cross-regime rule — it is the practical consequence of the fact that a policy insufficient for one member is non-compliant for that member, so the firm's policy must satisfy the more demanding regime.

Run-off

The ICAEW Regulations require two years of run-off cover from the date of cessation. ACCA's Practising Regulations require an equivalent period on cessation and impose the obligation on the practitioner or firm rather than on the incumbent insurer. Both regimes recognise that longer run-off may be prudent in specific circumstances but neither mandates it as a general rule. For firms with meaningful audit or tax-advisory exposure, extended run-off is a broker recommendation rather than a regulatory requirement under either regime.

Approved insurers

Neither ACCA nor ICAEW publishes a closed list of approved insurers in the way the SRA does for solicitors. Both rely on criteria — regulatory authorisation (PRA or FCA or equivalent EEA authorisation), financial strength ratings meeting a stated threshold, wording that meets the substantive requirements of the regulations. The practical difference is that the ACCA regime imposes some additional wording obligations around defence costs and the scope of "civil liability" cover that a wording must include, and firms placing ACCA-compliant cover should check that the insurer's standard wording either matches the requirements or is endorsed to do so.

Reporting

Both bodies require firms to confirm PII compliance annually. The ACCA confirmation is via the annual return; the ICAEW confirmation is via the annual return of practising certificates. Late renewal — where a firm's cover has lapsed and a new policy is not yet in place — is a reportable breach under both regimes.

What ACCA does that ICAEW does not, and vice versa

Two points of substantive difference are worth flagging. ACCA's Practising Regulations attach specific requirements to firms undertaking insolvency work regulated under the Insolvency Act 1986, including additional PI cover for the insolvency practitioner's licence — this echoes rather than replaces the RPB's own insolvency PI rules (the ICAEW, IPA and ACCA are all recognised professional bodies for insolvency purposes). Firms with insolvency practitioners need to consider both bodies' rules.

ICAEW's regulations, meanwhile, contain explicit provisions on how PII cover interacts with the Registered Auditor status many ICAEW firms hold. Firms conducting statutory audit work must ensure the PII policy meets both the ICAEW PII Regulations and the audit-specific expectations. ACCA has parallel provisions for its audit-registered firms.

Dual-regulated members and firms

A member holding both ACCA and ICAEW credentials — not uncommon — needs a policy that satisfies both regimes. In practice this is a wording question rather than a limit question: any wording that meets the more demanding of the two regimes on any given point (limit, run-off, defence costs, aggregation) satisfies the less demanding on that point. The firm's broker should be able to produce a written note confirming which regime drives each policy feature at renewal.

Worked example

Illustrative only. A three-partner firm has two ICAEW members and one ACCA member. Fee income £900,000. Under ICAEW: minimum £2.25m (2.5× fees). Under ACCA: minimum under ACCA's scaling regime for that fee band. Operative minimum is £2.25m — the higher figure. Broker places a £3m primary layer on a wording that includes explicit "defence costs in addition to the limit" language and meets both regimes' documentation requirements. Confirmation memo issued at binding.