
Strategy
Part of Accounting services strategy for assessing MTD support
Ninety days to test an accounting service, from verifying demand to deciding on scale
Use a 90-day accounting services plan for England to verify demand, define scope, install controls, pilot delivery and decide whether to scale.
This plan is for testing one clearly bounded service, not opening an unrestricted accountancy practice in three months. Regulatory, professional and insurance work may require longer. Do not accept customers until the relevant gates are complete.
What to take away
- Ninety days tests one bounded service, not an unrestricted practice, and regulatory work may take longer.
- Do not accept customers until every mandatory control has an evidenced go, wait or stop decision.
- Time the whole service and set a maximum pilot volume before accepting any customers.
- A weak offer should be stopped, and the schedule counts as successful when it does.
- Keep customer work segregated from test data and assign access before the pilot begins.
Days 1 to 15: define the decision
Choose the customer, trigger and accounting task. Write the completion evidence, exclusions and competence boundary. Review existing enquiries and interview actual or likely users, including people who chose another route. Define in advance what evidence will count as verified demand, such as a set number of interviews and a written commitment to proceed once the mandatory gates are complete.
Days 1-15: Define the decision
- Days 1-15Choose customer, trigger, accounting task
- Days 1-15Write completion evidence and exclusions
- Days 1-15Review enquiries and interview users
- Days 1-15Create source log for obligations
- Days 1-15Output research question and assumptions
Create a source log for every deadline or obligation. If the offer concerns 2027 MTD, use HMRC's current implementation guide and document which customer facts determine scope.
Output: an approved research question, audience screen and list of assumptions.
Days 16 to 30: settle authority and risk
Confirm the legal entity and professional claims, competence. Check practising certificate and designated professional body requirements with ICAEW, ACCA, AAT, CIOT or ICAS. Confirm supervision under the Money Laundering Regulations 2017 (as amended), including HMRC AML supervision registration or professional body supervision, and check the public supervisory register. Arrange professional indemnity insurance to the minimum terms required by the relevant body. Register with the ICO and comply with UK GDPR and the Data Protection Act 2018. For tax agent work, apply for an HMRC agent services account and use the agent authorisation process, form 64-8 or the Agent Services Account route. Map customer acceptance, identity, authority, conflicts and risk assessment.
Authority and risk controls
- Confirm legal entity and professional claims
- Check competence and supervision
- Verify tax-agent registration and insurance
- Map data protection and complaints
- Map acceptance, identity, authority, conflicts
- Record go, wait or stop decisions
HMRC's money laundering supervision guidance describes registration and supervision routes under the Money Laundering Regulations 2017, and the public supervisory register lists supervised businesses. Obtain qualified advice where applicability is uncertain.
Output: evidenced go, wait or stop decisions for every mandatory control.
Days 31 to 45: design the service
Map the workflow from qualification to closure. Name performer, reviewer and deputy. Prepare the engagement letter, record request, client timetable, approval language, change control and handover.
Design the service workflow
- Qualification to closure
- Name performer, reviewer, deputy
- Prepare engagement letter and record request
- Set client timetable and approval language
- Test ordinary, poor-record, deadline cases
- Remove steps that do not change action
- Output: versioned workflow and escalation map
Test the process using an ordinary case, a poor-record case and a deadline exception. Remove steps that collect information without changing an action.
Output: versioned workflow, templates and escalation map.
Days 46 to 60: prove systems and readiness
Configure software using the least access required. Test at least one mainstream bookkeeping product such as Xero, QuickBooks, Sage or FreeAgent, and the HMRC-recognised submission software you will use for Making Tax Digital and other filings. Test import, reconciliation, review, approval, submission acknowledgement, export, backup and restore. Run a supplier outage and account compromise exercise.
Prove systems and economics
- Configure software with least access
- Test import, reconciliation, review, approval
- Test submission acknowledgement, export, backup, restore
- Run supplier outage and account compromise exercise
- Time onboarding, questions, checking, correction
- Model transaction bands, software, insurance, supervision
- Set maximum pilot volume and intake stop point
Time the whole service, including onboarding, questions, checking and correction. Record the fee you will charge and the costs you will incur for software, insurance, supervision and acquisition, using your own quotes and invoices. Set the maximum pilot volume and intake stop point.
Output: tested system record, recorded costs and capacity calendar.
Days 61 to 75: run a limited pilot
Accept only customers who meet the approved criteria and can supply records by the cut-off. Explain that the service is a pilot without lowering professional standards. Review every high-consequence output and sample ordinary work.
Track missing information, rework, deadline margin, client effort, out-of-scope requests and incidents. Do not change the offer silently for one persuasive client.
Output: completed files, exception log and participant feedback.
Days 76 to 90: decide and stabilise
Reconcile promised scope against work performed. Review revenue only after all delivery and correction cost is recorded. Analyse declined and abandoned cases alongside accepted customers.
Choose one decision: continue unchanged, change and retest, narrow the audience, add supervision, refer a task or stop. Assign every improvement and repeat any failed control before increasing volume.
Output: signed decision note, revised plan and next review date.
The schedule is successful even when it stops a weak offer. Ninety days of disciplined evidence can prevent years of unclear scope, underpriced exceptions and unsafe deadlines.
Hold weekly decision reviews
Use a short record showing completed evidence, unresolved gates, approaching deadlines, capacity and decisions needed. Do not turn the meeting into a percentage-complete report. One unresolved supervision or security issue can matter more than dozens of finished marketing tasks.
Keep customer work segregated from test data and assign access before the pilot. At each review, inspect one file from source record to completion evidence. Ask whether another competent person could reproduce the result and continue the work if the owner were absent.
At day 90, archive the approved materials and set monthly controls for the next cycle. A continuing service needs monitored capacity, source updates and periodic file review after the launch project ends.
Before you act
- Define the customer, trigger and accounting task.
- Confirm authority, insurance and complaints arrangements, including HMRC AML supervision, practising certificate and ICO registration.
- Test the workflow with ordinary, poor-record and deadline cases.
- Time the whole service and record your own costs.
- Accept only pilot customers who meet approved criteria.
- Assign every improvement and repeat failed controls.
Common questions
What should be decided in the first fifteen days?
Choose the customer, trigger and accounting task, then write the completion evidence, exclusions and competence boundary. Review existing enquiries and interview actual or likely users, including people who chose another route. Create a source log for every deadline or obligation, and output an approved research question, audience screen and list of assumptions.
How should the pilot be run between days 61 and 75?
Take on only clients matching your agreed criteria who can deliver records on time. Call it a pilot, but keep professional standards. Check all high-risk outputs and sample routine files. Use named software such as Xero, QuickBooks, Sage or FreeAgent, and the HMRC-recognised submission software you will rely on.
What happens at the day 90 decision point?
Pick one route: carry on as is, adjust and test again, target fewer clients, add oversight, pass a task elsewhere, or halt. Assign improvements and repeat any control that failed. At this point, confirm that ongoing supervision, insurance and ICO registration remain current for the next cycle.



