Senior Accounting Officer (SAO)

Defining the Senior Accounting Officer (SAO) regime

The Senior Accounting Officer (SAO) regime is a corporate tax compliance requirement introduced by HM Revenue & Customs (HMRC) in the United Kingdom in 2009. It was designed to strengthen governance and accountability in large companies by ensuring that tax accounting arrangements are robust, accurate, and well controlled.

Under the regime, a qualifying company must appoint a Senior Accounting Officer, usually the Chief Financial Officer or another board-level executive, who is personally responsible for confirming that the company has appropriate tax accounting systems in place. Each year, the SAO provides HMRC with a Statement of Assurance, either confirming that arrangements are effective or highlighting any known weaknesses.

This link between senior leadership and compliance underlines the UK’s focus on strong corporate governance, transparency, and accountability in tax reporting.

Who is affected by the SAO regime?

The SAO regime applies to large UK-incorporated companies and to foreign companies with a UK permanent establishment that meet specific size thresholds. A company falls within the regime if, in the preceding financial year, it had:

• Turnover exceeding £200 million, or
• A balance sheet total exceeding £2 billion.

For corporate groups, the thresholds are considered on a group-wide basis, and each company that qualifies must appoint its own SAO. This ensures that accountability sits within each legal entity, even when oversight is provided at group level.

The SAO must be an individual officer of the company, not an external adviser. HMRC expects the person appointed to be closely involved in financial management and decision-making, typically a CFO, Finance Director, or Head of Tax.

Core elements of SAO compliance

The SAO regime requires more than an annual sign-off. It embeds accountability for tax processes into day-to-day governance. Key responsibilities include:

• Ensuring adequate arrangements: The SAO must establish and maintain appropriate tax accounting systems and controls for all relevant taxes, such as corporation tax, VAT, PAYE, and customs duties.
• Annual certification: The SAO must submit a Statement of Assurance to HMRC confirming that the arrangements are sufficient. If deficiencies exist, these must be disclosed.
• Transparency and record-keeping: The company must maintain adequate documentation to demonstrate that processes are monitored, tested, and capable of producing accurate tax returns.
• Continuous oversight: The SAO is expected to engage proactively with the business, ensuring that control frameworks evolve as tax rules and business structures change.

Failure to comply can have serious consequences. HMRC can impose personal penalties of £5,000 per failure on the SAO, in addition to potential penalties on the company itself. Beyond fines, companies risk reputational damage if HMRC perceives weaknesses in governance and tax compliance.

Why the SAO regime matters for corporate governance

The SAO regime highlights the UK’s emphasis on connecting senior management accountability with internal control environments. It encourages companies to:

• Strengthen their tax risk management frameworks.
• Align financial and tax reporting processes more closely with governance standards set by the UK Corporate Governance Code.
• Demonstrate to shareholders, regulators, and HMRC that they operate with integrity and transparency.

For many organizations, compliance with the SAO regime has acted as a catalyst to improve wider internal control and assurance processes across finance, risk, and compliance.

How Impero supports SAO compliance

Meeting SAO obligations requires consistent oversight, strong internal controls, and a transparent record of compliance activities. Impero helps companies strengthen their SAO compliance by:

• Centralizing control activities: Manage all tax-related processes in one platform for easier oversight.
• Automating workflows: Ensure that recurring tasks and reviews are completed consistently and on time.
• Enabling accountability: Assign clear ownership of controls to demonstrate accountability across the organization.
• Providing real-time visibility: Track the status of controls and processes, reducing the risk of errors or missed steps.
• Supporting documentation: Maintain a complete audit trail that makes it straightforward to evidence compliance and prepare the Statement of Assurance.

With Impero, companies can turn the SAO regime from a manual, resource-heavy exercise into an integrated part of their governance and compliance framework.

Get started with Impero for your SAO compliance

Are you looking to simplify your SAO compliance process and reduce the burden of annual reporting? Impero offers an intuitive, audit-ready platform that enables you to structure, automate, and oversee tax-related controls across your organization.

👉 Reach out to our team to discover how Impero can support your SAO compliance with automation, control ownership, and real-time visibility across your internal control environment.