Who counts as practising accountancy in Kenya
What section 19 of Kenya's Accountants Act treats as practising as an accountant, who is outside it, and why a certificate and licence are both needed.
By Achekam · · 5 min read · For Accountants & audit firms in Kenya
A CPA who works as a finance manager starts doing the books for a few small businesses at weekends. A tax consultant opens an office and offers to "verify" clients' accounts for a loan application. A recently qualified member puts "accountant" on a website and invites enquiries. Which of them is practising as an accountant in the sense that the law cares about?
The answer matters because practising without the right papers is a criminal offence in Kenya, not just a breach of the institute's rules. This article walks through the statutory definition, the people it leaves out, the two documents a practitioner needs, and how to check a firm's own service lines against them.
What section 19 says
The Accountants Act, 2008 sets out a definition in section 19. A person practises as an accountant if, for reward, they:
- offer or perform the auditing or verification of financial transactions, books, accounts or records;
- offer or perform the verification or certification of financial accounts; or
- hold themselves out to the public as entitled to practise accountancy.
Three features of that wording are worth noticing.
"For reward." The definition is framed around paid work.
"Offer or perform." Advertising the service counts, not only doing it. A firm that lists audit on its website is offering it, whether or not a client has accepted.
"Hold themselves out." The last limb catches presentation as well as work. Calling yourself a practising accountant in public, on a sign or a profile, brings you within the definition.
ICPAK states the same boundary from the membership side: a non-practising member may not offer audit or accountancy services to the public, because that requires a practising certificate. The categories of membership and what each allows are set out in ICPAK membership categories.
Who is not practising
Section 19 also says who falls outside the definition by reason of certain work alone.
- Salaried employees acting for their employer. A finance manager preparing their own employer's accounts is not practising as an accountant by doing so.
- Tax consultancy by advocates and secretaries. Neither an advocate nor a Certified Public Secretary is practising as an accountant merely because they offer tax consultancy.
The words "by that alone" carry weight. The finance manager in the opening example is outside the definition for the day job. The employee exclusion says nothing about auditing or verification done for outside clients for reward, or about presenting oneself to the public as an accountant. An advocate whose services stop at tax advice is outside it; one who begins verifying accounts for reward is not protected by the exclusion.
A certificate and a licence, both in force
Falling within the definition is not itself a problem. Doing so without the right papers is. Section 18 of the consolidated Act on Kenya Law, in the version dated 20 June 2025, says no person may practise as an accountant unless they hold a practising certificate and a licence to practise, both in force.
The licence has its own cycle. Under section 22, a practising certificate holder who intends to practise as a firm, alone or in partnership, must obtain an annual licence. It is valid until 31 December of the year of issue and must then be renewed. A certificate without a current licence does not meet the test, and neither does a licence that expired at the end of last year. Which licence category fits which work is explained in ICPAK licence categories A, T, M and C.
The penalty
Practising without a certificate and licence in force is an offence under section 18, punishable by a fine of up to five hundred thousand shillings or imprisonment for up to three years. The prohibition is addressed to each person, so the licences of other partners in the same firm do not cover someone whose own papers are missing.
The full text of sections 18, 19 and 22 can be read on Kenya Law's page for the Accountants Act, which sets out how ICPAK registers accountants and issues practising certificates and annual licences.
Recording registrations in Achekam
A firm on Achekam keeps a record of who is entitled to sign. Staff record the firm's ICPAK firm licence and each signing professional's registration, and a different person must verify each one against the official register with dated evidence. Achekam does not look these up online; its "check online" call always answers UNAVAILABLE, so the verification is a person's check that the platform records.
For audit reports, Achekam goes a step further. It blocks signing of a Kenyan audit report until the signer's ICPAK practising certificate and annual licence are recorded and verified by a different person at the firm, and the firm must also record the signer's audit signing authority. A missing firm licence gives only a warning. The way that block works day to day is described in the ICPAK certificate check before signing.
That check covers signing. It does not police the wider definition: the platform cannot tell whether a staff member is offering verification work to outside clients at weekends. That remains a matter of firm policy.
Reviewing your service lines against section 19
Run through these questions for the firm and for each person who deals with clients:
- Which services do we offer for reward that involve auditing or verifying transactions, books, accounts or records?
- Do we verify or certify financial accounts for anyone, such as for loans, tenders or grants?
- Who holds themselves out as an accountant on our website, letterhead, e-mail signatures and profiles?
- Does each of those people hold a practising certificate and a current annual licence?
- Are any staff doing outside work that could bring them within section 19 personally?
- Who in the firm checks that licences are renewed before 31 December each year?
Questions three and five are the ones most often skipped, because they concern how people present themselves rather than the work the firm sells.
Where to start
Begin with the public face of the firm. Read the website, letterhead and staff e-mail signatures with section 19 in mind, and confirm that everyone presented as practising has a certificate and licence in force today.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
