Reviewed by Apex Insurance Brokers · Last reviewed 2026-06-22
The Institute of Chartered Accountants in England and Wales (ICAEW) sets the PI minimums for its member firms through the ICAEW Professional Indemnity Insurance Regulations. Since 1 September 2024 the headline requirement is: a firm with gross fee income under £800,000 must hold 2.5 times that income, with a minimum of £250,000; every other firm must hold at least £2 million for any one claim and in the aggregate. The £2 million figure does not stop a firm from buying more; it is the regulatory floor.
Gross fee income for the purpose of the Regulations is the total fee income of the firm's accountancy and related services in the most recent completed financial year. Disbursements recharged at cost are typically excluded. Income from work that is not accountancy-related — for example, separate property income or unrelated consultancy outside the firm's accounting practice — is excluded from the calculation.
A firm with £80,000 of gross fee income must hold at least £250,000, because 2.5 times £80,000 is £200,000, below the floor. A firm with £400,000 of fee income must hold at least £1 million (2.5 times £400,000). A firm with £800,000 or more of fee income must hold at least £2 million for any one claim and in the aggregate, and that stays the minimum at £2 million or £5 million of fees.
The minimum applies for any single claim and in the aggregate, so ICAEW accepts cover written on either an aggregate or an each-and-every-claim basis. Each-and-every cover can give more protection in total if several claims arise in one policy year. Check how your policy treats defence costs, because costs paid inside the limit reduce what is left for damages.
Run-off is required for at least two years after the firm ceases to engage in public practice, and the former principals must then take all reasonable steps to keep cover for a further four years. This is shorter than the architect, surveyor, or solicitor run-off requirements, but ICAEW members may need to consider longer cover where they have advised on tax positions that could be reopened under HMRC's discovery powers in section 29 of the Taxes Management Act 1970, or on transactions that may attract claims well beyond a two-year horizon.
Many ICAEW firms now run a substantial consultancy arm alongside the accountancy practice — strategy, finance transformation, restructuring, interim FD work. The Regulations apply to accountancy and related services; pure consultancy may fall outside. Where it does, a separate consultancy PI wording may be needed, or the policy may need to be extended to cover the broader activity.
Our accountants PI insurance guide covers the Regulations in detail and explains how insurers typically treat the boundary between accountancy and consultancy. Firms with a significant management-consultancy practice may also want to read our management consultants PI insurance guide, which sets out the wordings used in that market and the cover gaps that can arise when accountancy and consultancy are bundled into one policy.
Firms holding a Designated Professional Body (DPB) licence to carry out non-mainstream regulated activities under the Financial Services and Markets Act 2000 sit under a separate, narrower regime. The PI cover must extend to the DPB activities, and the firm must hold the DPB licence in addition to its ICAEW practice authorisation. A breach of the DPB conditions is a separate disciplinary issue.
The ICAEW Regulations require firms to notify circumstances to insurers as soon as reasonably practicable. Delays can prejudice the insurer's position and provide grounds for the insurer to argue prejudice under section 11 of the Insurance Act 2015 — or under common-law non-disclosure principles where applicable.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email info@apexinsurancebrokers.co.uk, or request a quotation.
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