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A Senior Accounting Officer (SAO) is the director or officer of a company who, in the company’s reasonable opinion, has overall responsibility for the company’s financial accounting arrangements.

Each qualifying company, see SAOG11100, must identify who its SAO is. »Ê¹ÚÌåÓýapp company’s opinion must be a reasonable one.

Except in very unusual circumstances a qualifying company will always have an SAO. Where a Customer Compliance Manager (CCM) or the Mid-sized Business Customer Engagement Team receives a claim that there is no SAO for a qualifying company, see SAOG16400.

»Ê¹ÚÌåÓýapp identity of the SAO can change, see SAOG12500.

Where a group of companies is involved, there may be

• a different person who acts as SAO for each company,
• a single person who acts as SAO for all the group companies or
• several different persons who act as SAOs for different parts of the group.

Note that because the SAO must be a director or officer of the company, this responsibility cannot be delegated to an agent or advisor of the company. However where a company is in administration or liquidation, the administrator or liquidator may be the SAO. If they are not, they should be ‘the responsible person� able to identify who is.

For the purposes of the SAO provisions, a company can only have one SAO at any stage.

It is in a company’s interests to identify who their SAO is at an early stage in their financial year. That person can then undertake the responsibilities set out in the SAO provisions.