Rules and ethics
Part of Accounting services rules and ethics: a practical framework
Accounting services advertising rules: what to check before an advert goes live
A UK checklist of accounting services advertising rules covering ASA and CAP Code claims, company disclosures, reviews, referrals and email marketing.
Use this accounting services advertising rules checklist to review every page, advert, directory field, email and referrer script (the wording a referrer or affiliate uses) before it reaches customers. The checklist is a publication control, not legal advice. Check the laws and professional rules that apply to the service and channel.
What to take away
- Check every page, advert, directory field, email and referrer script before it reaches customers.
- Hold evidence for savings, speed, accuracy or success claims before publishing them.
- State whether a price is fixed, starting, estimated or a work-unit price.
- Use “Chartered Accountant” or “Chartered Certified Accountant” only where the person is entitled to the title; advertise statutory audit only where the firm is registered to provide it.
- Record claim, evidence, owner, approval, channel and expiry, then recheck on publication day.
Identify the advertiser and service
- State the legal entity and trading name accurately.
- Give a usable contact. For a limited company, include its registered name, company number, place of registration and registered office address on its website and relevant business documents where required. Check the Companies Act 2006 and Companies (Trading Disclosures) Regulations 2008 (as amended), and verify company details at Companies House.
- Name the service rather than relying on "complete accounting" or "full support".
- Separate bookkeeping, accounts preparation, payroll, tax compliance, advice and statutory audit.
- State the customer and geographic scope.
- Check that the delivery team can perform every advertised activity.
Substantiate objective claims
- Hold evidence before publishing savings, speed, accuracy or success claims.
- Define the measured population, period and calculation.
- Retain current evidence for qualifications, memberships and software partnerships.
- Verify audit registration independently if statutory audit is advertised. Check the firm's entry on the Financial Reporting Council's Register of Statutory Auditors; audit registration is through a recognised supervisory body.
- Avoid "leading", "largest" or "best" without evidence for the likely interpretation.
- Put material limitations next to the claim, not on a remote page.
The Advertising Standards Authority (ASA) administers and enforces the non-broadcast CAP Code. Read the whole Code, not just section 3: section 1 covers compliance, section 2 recognition of marketing communications, and other sections may apply depending on the advert. Section 3 addresses misleading advertising, substantiation, qualifications, comparisons and testimonials. A qualification can clarify a claim but should not contradict its main message.
Substantiate objective claims
- Hold evidence before publishing savings claims
- Define measured population, period, calculation
- Retain evidence for qualifications and memberships
- Verify audit registration independently
- Avoid leading or best without evidence
- Put material limitations next to claim
Present price and scope together
- State whether the figure is fixed, starting, estimated or a work-unit price.
- Identify VAT treatment and contract period where relevant.
- Explain transaction, payroll, entity, software or record-quality assumptions.
- Separate onboarding, clean-up, filings, advice and additional work.
- Disclose renewal, cancellation and scope-change terms that affect the headline.
- Keep the evidence date beside time-limited offers.
Do not advertise an entry fee obtained from a simple case as the typical cost for materially different customers.
Present price and scope together
- State fixed, starting, estimated or work-unit
- Identify VAT treatment and contract period
- Explain transaction, payroll, entity assumptions
- Separate onboarding, clean-up, filings, advice
- Disclose renewal, cancellation, scope-change terms
- Keep evidence date beside time-limited offers
Control professional and regulatory wording
- Use protected designations only with verified entitlement and approved form.
- Do not imply that HMRC endorses, approves or appoints the practice.
- Distinguish AML supervision, tax-agent registration and professional membership.
- Avoid suggesting that supervision is a quality rating.
- Make clear when a service is delivered by a partner or separate legal entity.
Check the current requirements of the professional body whose membership or designation you advertise. Relevant bodies and conduct codes include ICAEW's Code of Ethics, the ACCA Rulebook (including its Code of Ethics and Conduct), AAT's Code of Professional Ethics, CIOT's Professional Conduct in Relation to Taxation, ICAS's Code of Ethics and CIPFA's Code of Ethics. The Register of Statutory Auditors is maintained by the Financial Reporting Council; check the register rather than relying on a general claim of audit expertise.
Accountancy service providers may have AML supervision through HMRC or a relevant professional body, including ICAEW, ACCA, AAT, CIOT, ICAS or CIPFA. The FCA supervises firms within its regulated financial-sector remit; it is not a universal AML supervisor for accountants. HMRC's Agent Services Account, where used to access HMRC online services, is separate from AML supervision and professional membership.
If an advert promotes investment advice or other investment activity, check section 21 of the Financial Services and Markets Act 2000 and the FCA's financial-promotion rules. Mortgage promotions have separate FCA Mortgage Conduct of Business (MCOB) requirements, so check those when advertising mortgage advice.
HMRC's agent standard specifically warns agents against implying HMRC endorsement. Reopen the current text before publication.
Review testimonials and comparisons
- Keep evidence that a testimonial is genuine and permitted.
- Make sure it relates to the advertised service.
- Substantiate measurable factual claims inside customer wording.
- State incentives or material circumstances affecting a review.
- Apply consistent criteria and dates to named competitors.
- Do not remove genuine criticism in a way that makes the displayed sample misleading.
Disclose directories and referrals
- Label sponsored or paid positions prominently.
- Explain ranking and inclusion criteria.
- State whether a directory verifies, checks or merely receives provider statements.
- Disclose referral or affiliate payments where material.
- Prevent partners from making unapproved promises about scope or deadlines.
- For marketing emails, check the Privacy and Electronic Communications Regulations 2003 (PECR) and the Information Commissioner's Office (ICO) direct-marketing rules, including which consent and opt-out requirements apply to the recipient.
For consumer-facing claims, check the unfair-commercial-practices rules in Part 4, Chapter 1 of the Digital Markets, Competition and Consumers Act 2024, which replaced the Consumer Protection from Unfair Trading Regulations 2008. The Competition and Markets Authority's guidance on reviews and endorsements is relevant when displaying customer reviews or endorsements. Check how the rules apply to the actual audience and presentation.
Approve and monitor
Record claim, evidence, owner, approval, channel and expiry. Recheck dynamic prices, staff, awards, law and filing dates on publication day. Monitor complaints and misunderstood enquiries for signs that technically correct words create a misleading overall impression.
Remove or correct an unsupported claim promptly and preserve the previous version. Advertising control is complete when another reviewer can trace every material statement to current evidence.
Include referrers and affiliates in monitoring. Give them approved current wording, an expiry date and a route for questions. If a third party continues to promise guaranteed savings, HMRC approval or unavailable services, suspend the relationship and preserve the evidence for appropriate review.
Before you act
- Name the service rather than relying on vague phrases.
- Put material limitations next to the claim.
- Disclose renewal, cancellation and scope-change terms that affect the headline.
- Label sponsored or paid positions prominently.
- Give referrers approved current wording and an expiry date.
- Remove or correct an unsupported claim promptly.
Common questions
What must be checked before an accountancy advert goes live?
Review every page, advert, directory field, email and referrer script before it reaches customers. The checklist is a publication control, not legal advice. State the legal entity and trading name accurately, and give a usable contact. For a limited company, include its registered name, company number, place of registration and registered office address on its website and relevant business documents where required; check the Companies Act 2006 and Companies (Trading Disclosures) Regulations 2008 (as amended).
How should price and scope be presented together?
State whether the figure is fixed, starting, estimated or a work-unit price. Identify VAT treatment and contract period where relevant, and explain transaction, payroll, entity, software or record-quality assumptions. Separate onboarding, clean-up, filings, advice and additional work, and disclose renewal, cancellation and scope-change terms that affect the headline.
What is required for testimonials and comparisons?
Keep evidence that a testimonial is genuine and permitted, and make sure it relates to the advertised service. Substantiate measurable factual claims inside customer wording, and state incentives or material circumstances affecting a review. Apply consistent criteria and dates to named competitors, and do not remove genuine criticism in a way that makes the displayed sample misleading.
