The FCA rules do not dictate whether the firms that they regulate need statutory audits of their accounts – the rules are set out in company law.

Small entity audit exemption

UK company law allows some FCA-regulated entities that are members of small groups to take advantage of statutory audit exemption, however some FCA-regulated entities are not eligible for this exemption.

To qualify as small, the whole worldwide group must meet two out of the three following criteria for two years in a row:

*The new thresholds apply to financial years beginning on or after 6 April 2025.

If the group is small, what else applies to FCA-regulated entities?

Entities in some small groups are not allowed to take advantage of this audit exemption.

This includes groups where any entity is:

• a MiFID investment firm;

• a UCITS management company;

• authorised under the Banking Consolidation Directive or the Insurance Directives;

• an e-money issuer; or

• listed on a UK regulated market such as listed on the London Stock Exchange, AQUIS Stock Exchange or ICE Futures Europe

Is my firm a MiFID investment firm?

MiFID investment firms are defined by the type of activity they have permission to perform. Broadly speaking, if your firm is in scope of the Investment Firms Prudential Regime (IFPR), The Prudential sourcebook for MiFID Investment Firms (MIFIDPRU) will apply, and your firm is a MiFID investment firm.

A firm that was previously an “Exempt CAD” firm could consider whether it is possible to opt out of being a MiFID investment firm.

If you would like more information on whether your firm is exempt from audit, please get in touch using the form below.

What do I need to do if my FCA-regulated firm is not exempt from audit?

The company’s directors, or LLP’s designated members, must appoint a UK statutory auditor. The auditor will report on whether or not the accounts are “true and fair”. This report will be included with the accounts when they are submitted to the FCA and sent to shareholders, Companies House (for filing on public record) and HMRC (with the tax return).

The firm may also be required to get a Client Asset (“CASS”) audit, even if the firm does not have permission to hold client money. Buzzacott’s specialist financial services audit team can guide you through the requirements for audit and CASS audit.