CAA ATOL Reporting Accountants' Scheme

AIA has signed a memorandum of understanding with the Civil Aviation Authority (CAA) and agreed the process for AIA members to apply to be licensed under the ATOL Reporting Accountants' scheme.

If you want to act for your ATOL licence holders and submit ATOL Accountants’ Reports to CAA, you must be an ATOL Reporting Accountant.

The scheme will ensure that the professional bodies provide the appropriate level of continuing professional development (CPD) in order to best equip their members to successfully undertake ATOL work. It also means that professional bodies will have in place a more professional regime that focuses on the demonstration of competence, helping to reduce overall risks in the market of reporting false or inaccurate financial information by ATOL holders.


Registration with and licensing by AIA is open to members who:

  • Hold an AIA practising certificate
  • Have taken and passed a professional examination covering assurance work as approved by the CAA. For AIA members this is paper 15 Professional Practice. If you have taken another professional qualification (or part of), recognised by CAA,  please contact AIA for further information.

Registration Requirements

The basic requirements of the Key Components document are that:

  • each principal in the firm should be subject to disciplinary arrangements
  • there should be at least one designated ATOL reporting accountant for the relevant category of registered ATOL work.

In addition, the firm must demonstrate that:

  • it has PII that is at least sufficient to cover the liability cap in the CAA Guidance Note 10
  • the principal business of the firm is the provision of accountancy services
  • it is independent of the ATOL holder
  • it has appointed a contact principal.

The ATOL reporting accountant is also expected to demonstrate competence and must:

  • have reviewed guidance (including but not limited to Guidance Note 10 - Advice for Accountants) issued by CAA ATOL and their professional body for ATOL reporting accountants
  • have successfully completed the CAA ATOL training package (as updated from time to time) and the training package and assessment has been shared with the professional bodies within this arrangement
  • have taken and passed a professional examination covering assurance work as approved by the CAA (this may be limited to individual modules of a professional qualification but must include an assurance qualification)
  • be a member of an approved professional body, as determined by CAA, and hold a practising certificate where required by the professional body.

 The individual designated ATOL Reporting Accountant must be independent of the ATOL holder.

Ongoing requirements

  • A firm must make arrangements so that all members, principals and employees performing ATOL-related work are, and continue to be, competent to carry out ATOL reporting for which they are responsible or employed.
  • The individual must also meet the continuing professional development guidelines of its professional body for the purposes of ATOL reporting.
  • A firm must maintain an appropriate level of competence in the conduct of ATOL work and this is best achieved through the use of relevant and bespoke manuals, programmes, checklists and procedures so that the firm has a body of knowledge. Such documentation must be kept up to date if the firm is to retain its competence.

AIA monitoring and disciplinary

Under this agreement and in line with AIA’s regulations, AIA is responsible for granting rejecting or withdrawing a member’s ability to perform ATOL reporting. AIA can also impose restriction or conditions on a member.

AIA will use its own regulations, policies and procedures to determine whether a member has breached a provision of the AIA’s registration arrangement rules and the matter will be dealt with under the disciplinary arrangements.  The professional body will determine whether a firm/designated ATOL reporting accountant is liable to disciplinary action under the professional body’s disciplinary arrangements if:

  • it has performed its ATOL reporting work inefficiently or incompetently to such an extent as to bring discredit on itself/him/herself, or
  • if it has breached any of the provisions of the registration arrangement.

A firm must appoint a contact principal who will supply the AIA with information as required and provide an annual declaration to the professional body of the individual designated ATOL reporting accountant compliance with its responsibilities under the registration arrangement rules. This is in addition to the AIA’s annual return and practising renewal documents.

Standards and guidance

The ATOL reporting accountant must review and be familiar with Guidance Note 10 - Requirements for ATOL Reporting Accountants, which is published in Official Record Series 3, as well as the Annual Accountants' Report, which is required to be completed as a term of holding an ATOL. these documents can be found on the links below:

Official Record Series 3

AAR Part 1 and Part 2 are available via the CAA online portal. 

AAR FAQ's for ATOL holders

A designated ATOL reporting accountant must:

  • act in accordance with the International Ethics Standards Board for Accountants Code of Ethics for Professional Accountants an
  • comply with any additional conduct of business requirements that are set out in the registration arrangement rules of the professional body for an application to become a designated ATOL reporting accountant.
  • A designated ATOL reporting accountant should follow Guidance Note 10 when performing ATOL returns/reporting work. 

Under the ARA scheme, the firm should take responsibility for firm-wide elements including:

  • policies and procedures
  • work programmes
  • internal compliance reviews
  • firm-wide training
  • fit and proper declarations.

The individual designated ATOL reporting accountant will sign off ATOL reports.


  • Sign off ATOL reports
  • Registration Requirements
  • Ongoing Requirements
  • Monitoring and Supervision