Reviewed by Matthew Bartlett, Director · Last reviewed 8 July 2026
If a client has written in threatening a claim, if HMRC has raised a discovery assessment that a client says was your fault, if a complaint has arrived at the firm that could develop, or if you have identified something in a completed file that you would rather your PI insurer knew about, this entry sets out how a UK accountant should think about the next 24 to 48 hours. It covers notification under the claims-made wording, why timing is critical, what the ICAEW or ACCA expect in parallel, and what your broker does at this point. Read it once, then pick up the phone.
Accountants' PI is written on a claims-made basis. The wording responds to claims and to notified circumstances during the period of insurance. It does not respond to matters that arose during it but were never told to the insurer. Section 3 of the Insurance Act 2015 imposes the duty of fair presentation at inception, renewal and any material variation; section 13A of the Act gives the insured a route where an insurer has breached the implied term to pay claims within a reasonable time. Late notification is one of the single largest technical reasons claims run into difficulty at coverage stage. Notifying does not commit you to admitting anything — it preserves the year's cover.
A claim under an accountants' PI wording does not have to be a court proceeding. It can be a letter from a client, an email from a client's new accountant asking pointed questions about a prior-year return, a formal complaint into the practice, an HMRC notice that the client attributes to advice you gave, or a note in a file that a reasonable partner or director in the firm would read as something that might turn into a claim. The wording standard is that a fact, matter, event or circumstance which may reasonably be expected to give rise to a claim must be notified. The test is objective, and once someone senior in the firm has identified it the practical clock has started.
ICAEW Bye-law 61 requires members in practice to hold PI cover meeting the Institute's minimum requirements as set out in the ICAEW PII Regulations. ACCA imposes a parallel requirement through its Global Practising Regulations. The DPB (Investment Business) licence for firms licensed for regulated non-mainstream financial services carries its own claims and complaint expectations. Alongside the PI wording, the ICAEW's disciplinary framework and the ACCA's Complaints and Disciplinary Regulations may run in parallel with a civil claim. Where a matter touches on money laundering, the CCAB anti-money-laundering guidance and the relevant Money Laundering Regulations obligations frame the regulatory response. A notification to your insurer and any parallel report to your professional body are separate exercises; both may be needed.
Do not respond to the client, HMRC or a claimant's adviser on substance until you have notified your broker. Preserve every working paper, email and note; do not tidy up a file or annotate a prior working paper after the event. Do not admit liability, offer a fee reduction that reads as an admission, or float a settlement figure in correspondence. Notify your broker straightaway; the broker handles the notification to the insurer in the form the wording requires and manages what happens next. If the underlying matter has a live tax deadline, an appeal window or a filing deadline running against the client, tell the broker in the first conversation — that changes the sequence. If the same conduct may need self-reporting to ICAEW or ACCA under the reporting rules, treat that as a separate track.
A named broker who has run accountants' notifications before will take the summary from you, prepare and submit the notification to the insurer in the form the wording requires, protect your position on scope and late-notification questions, and manage the appointment of defence solicitors from the insurer's approved panel. From there the broker handles any reservation of rights letter, the reserve conversation and any coverage questions that surface as the matter develops. On aggregation — where a series of related engagements or a common systemic error across multiple clients is being treated as one claim — the broker frames the argument with the insurer at the earliest stage. Apex is a broker, not an insurer or a defence firm; the broker handles the notification and manages the process with the insurer's appointed defence panel. This is the technical work where broker experience matters most.
Not because Apex clients never have claims. Accountants have claims — tax positions, audits, corporate finance, insolvency, all of them carry exposure by design. Apex clients renew because when a matter arose, the notification was made properly, the year's cover attached, and the firm arrived at renewal in a position to place terms on the merits rather than under a cloud.
Notification urgent?
If a matter has just arisen, call now. Late notification is one of the largest single reasons claims get declined. A named broker will pick up the phone and start the notification with you.