Understanding ACCA’s Client Money Regulations: How Telleroo Fits Into Your Accountancy Practice

For many accountancy firms, managing client payments feels like a natural extension of their bookkeeping or payroll service. After all, if you're already preparing supplier payments or processing payroll, why not help clients get those payments made too?

But there's often one question that stops firms going any further: does getting involved in payments mean you're holding client money and taking on additional regulatory responsibilities?

For ACCA-regulated firms, the distinction between preparing payments, authorising payments and actually holding client funds is particularly important.

Where ACCA's client money rules live

ACCA's client money rules sit within the Code of Ethics and Conduct, which forms part of the ACCA Rulebook. Two sections are relevant:

• Section A, IESBA Section 350 (Custody of client assets). ACCA has adopted the IESBA Code in full. Section 350 establishes a core principle: a professional accountant shall not assume custody of client monies or other assets unless permitted by law, and holding client assets creates self-interest threats to objectivity and professional behaviour.
• Section B18 (Custody of client assets). This is ACCA's own supplementary material for members in public practice. It contains the detailed clients' money rules covering client bank accounts, withdrawals, interest, and record-keeping. From 1 July 2025, ACCA restructured this content , previously held in italics within Section 350, and moved it to the new Sections B14 to B18.

Where Section A and Section B differ, the more stringent requirement applies. The Code is binding on all ACCA members, affiliates, registered students, and ACCA firms. Principals are responsible for ensuring that non-ACCA principals and staff comply too. Failure to comply can result in disciplinary action.

ACCA also publishes a guidance factsheet, Obtaining professional work, which summarises the clients' monies rules. It carries no regulatory status — the Rulebook takes precedence.

What counts as clients' monies, and what you must do if you hold them

Section B18 makes a member in public practice strictly accountable for all clients' monies they receive. Clients' monies means all monies received by the member to be held or disbursed on the instructions of the person from whom, or on whose behalf, they were received. This includes insolvency monies and money held as stakeholder. It does not include fees paid in advance for agreed work, though those must be refunded if the work is not completed, and the firm must have the resources to do so.

If your firm receives clients' monies, B18 sets out a clear list of obligations:

• A separate client bank account, with the word "client" in its title, into which clients' monies are paid without delay. Accounts may be general or designated to a named client.
• Written notice to the bank about the nature of the account, with written acknowledgement of the terms from the bank.
• A designated account for larger balances. Sums exceeding £10,000 (or equivalent) for a single client, expected to be held for more than 30 days, must sit in an account designated to that client.
• Mixed receipts must go into the client account first, with the firm's share withdrawn afterwards. Nothing other than clients' monies may be paid into a client account.
• Strict limits on withdrawals. Money may only leave a client account for payments to or on behalf of the client, debts due to the firm, properly earned fees, or on the client's authority, and never more than the balance held for that client.
• Taking fees requires written notice to the client, express authorisation by a principal, and either 30 days elapsed without objection or the amount agreed in writing or set by a court or arbitrator. You cannot withhold money due to a client because of a fee dispute.
• Interest paid to the client at no less than the bank's small-deposit rate, unless the client agrees otherwise in writing.
• Trust monies kept separate, with a dedicated client account for each trust.
• Bank charges on client accounts paid from the firm's own account.
• Reconciliations at least every 50 days, with records retained for at least six years from the last transaction.
• Untraceable funds may only be withdrawn with ACCA's written authorisation, which may require payment to a charity that provides an indemnity.

For many smaller firms, this is a significant regulatory and administrative burden, which is precisely why understanding what sits inside and outside these rules matters.

How Telleroo approaches payment management

Telleroo takes a different approach to payment processing, one that's designed with accountants and bookkeepers in mind.

With Telleroo, your firm can set up an e-money account for each client. The key distinction is ownership: each account is opened in the client's business name and is owned by the client, not your firm. Any funds in the account belong to the client and remain under their control at all times.

In practice, your role is operational support. You prepare pay runs, for payroll or supplier payments, and submit them for the client's approval. The client tops up their own account and approves payments directly. Your firm never receives the funds, never holds them, and never makes the decision to move them.

This is structurally different from a traditional client bank account, where funds pass through an account held in the firm's name and the firm carries full accountability for them. With Telleroo, that accountability stays exactly where it should: with the client.

Why Telleroo generally sits outside Section B18

Every obligation in B18 is triggered by one event: the firm receiving clients' monies. The definition covers money received by the member to be held or disbursed on the client's instructions. The account rules apply to money the firm pays in. The reconciliation and interest obligations apply to money the firm holds.

Where Telleroo is used on a submission-only basis, with funds held in the client's own account and payments authorised by the client, your firm does not receive or hold those funds. This is an important distinction from traditional client money arrangements and will help to avoid the additional obligations associated with holding client money directly.

Unlike the AAT and ICAEW rules, ACCA's Code does not include a specific paragraph on members operating a client's own bank account. The position for ACCA members therefore rests on the definition itself rather than an explicit carve-out. The conclusion is the same, but the reasoning is worth being clear on: your firm sits outside B18 because it does not receive or hold the money, not because ACCA has written a rule that says so.

The line not to cross: approver access

There is one scenario that changes the picture: a member of your firm being set up as an approver of the client's pay runs. Telleroo strongly recommends against this arrangement, and for ACCA members there are two specific reasons.

First, Section 350 of the IESBA Code is framed around custody of client assets, not just receipt. It makes clear that holding or controlling client assets creates a self-interest threat, and it requires the member to consider the source of funds and any relevant legal or regulatory obligations before taking on such a role. If your firm can release payments from a client's account without the client's involvement, a reasonable and informed third party could view that as a degree of control over the client's money. ACCA has not published guidance on exactly where that line falls.

Second, because the Code contains no explicit rule on signatory or approver arrangements, there is no safe harbour to rely on. The prudent position is to treat approver access as bringing you closer to the custody principles in Section 350 and to avoid it unless you have taken advice.

Keep the client as the approver, and the arrangement remains clean. If your firm's circumstances genuinely require approver access, document the client's written authority, maintain full transaction records, and contact ACCA's Technical Advice and Support before proceeding.

Practical safeguards to keep in place

Even where B18 does not apply, strong practice protects both your firm and your clients. Follow these steps to stay on solid ground:

• Keep the client as the sole approver of all pay runs.
• Set out the payment-support service clearly in your engagement letter, which the Code requires in any case. State explicitly that the client owns the account and authorises every payment.
• Retain records of what your firm prepared and when the client approved it.
• Never allow client funds to pass through an account in your firm's name. The moment they do, B18 applies in full and the money must be paid into a client account without delay.
• Continue to meet your anti-money laundering obligations under Section B2 of the Code. Client due diligence applies regardless of how payments are made, and you should remain alert to unusual transactions in a client's payment runs.

Final thoughts

When Telleroo is used as intended, with the client owning the account and approving every payment, your firm never receives clients' monies. That means the detailed requirements of Section B18 are not engaged. You avoid the client bank account, reconciliation, interest, and fee-withdrawal obligations that come with holding client money.

Because ACCA's Code does not spell out a specific position on members operating a client's own account, this is an area where care pays off. If any aspect of your service gives your firm the ability to move a client's money independently, speak to your professional indemnity insurer and contact ACCA's Technical Advice and Support before proceeding.

Telleroo is built to help accountants and bookkeepers manage payroll and supplier payments efficiently, securely, and without adding regulatory complexity. It's a smarter way to support your clients, without taking on the risks that come with holding their money.

This article is general guidance based on the ACCA Code of Ethics and Conduct (Section B18 effective 1 July 2025) and ACCA's Obtaining professional work factsheet (1 July 2025). It is not legal or regulatory advice.