COVID-19 and statutory filing deadlines

With so many firms now past the end of their financial year, apart from the challenging in-tray that most partners and financial directors will have, there is also the need to think about annual filing requirements.

Companies House are granting automatic three-month extensions to filing deadlines for company accounts as a result of COVID-19, and we had expected to see something similar from the SRA in respect of the annual accountant’s report. However, their website states that solicitors ‘must do everything they reasonably can to comply with our rules, and follow our principles’. Sean Hankins attended a virtual branch meeting of the ILFM on Friday 17 April and confirmed that the SRA had not wanted to give a blanket extension to all firms. That being said, they will be taking a pragmatic approach during this period of time, and that they appreciate for many firms the six-month filing deadline may not be achievable. If it does take longer, firms need to contact the SRA to explain, with good reason, and the SRA will not consider this to be a reportable breach of the rules.

Three things that you should be considering in advance of this year’s audit:

Have you updated your office manual for any exceptional systems and procedures you have had to implement during this time? There is no need to re-write the entire office manual, but may be worth adding an addendum where applicable.
Have you contacted your system provider to see whether your accountants can be given remote access to your accounting and case management softwares, so that the work might be started even if an on-site visit is not yet possible?
Do you operate a document management system, or are all client files paper-based? There has been some discussion about scanning in files to send to accountants or even posting hard copy files. There are understandably some concerns here around GDPR, etc. We are still hoping we will be able to visit firm’s offices to carry out physical verification, but will be trying to do as much work remotely beforehand as possible.