Achekam

Two-person rules for a sole practitioner

Where Achekam insists on a second person, and how a sole practitioner can still prepare, review and sign by using attestations, staff and other firms.

By Achekam · · 5 min read · For Accountants & audit firms in South Africa, Nigeria, Kenya

sole practitioner review segregation of duties

A sole practitioner knows every client personally, answers every query and signs every report. That closeness is the practice's strength. It is also why so many controls designed for larger firms, which depend on one person checking another, can feel like they were written for someone else.

Achekam builds a second pair of eyes into many steps. For a two-partner firm that is a convenience. For a practice of one, it raises a fair question: how do you finish an engagement when the system keeps asking for somebody who does not exist?

The answer is a mix of planning, a few written attestations, the people you already have, and other firms. This article goes through each.

Where Achekam asks for a second person

It helps to know exactly where the second person is required before deciding how to supply one.

StepThe ruleWho can be the second person
Working papersThe preparer cannot also review a paperAny colleague who did not prepare it
Financial statementsOnly a partner signs; the recorded preparer or reviewer cannot issueThe practitioner signs if someone else prepared or reviewed
Working-paper profileAnother person approves the profileA sole practitioner may approve with a written attestation
MaterialityThe engagement partner approves, never the preparerA staff member prepares the proposal
Engagement quality reviewA partner or senior manager not on the teamOften nobody inside a one-partner firm
Payroll (South Africa)The preparer cannot approve a runA second person in a payroll role
TimesheetsBy default, time becomes billable after someone other than its recorder approves itA manager or administrator

Two things stand out. First, most of these rules are satisfied by any other person in the firm, not necessarily a qualified one. Second, only one of them comes with a written exception for a sole practitioner.

The attestation for a working-paper profile

When staff generate an engagement's working papers from the methodology, Achekam reads the engagement's facts, a person confirms what it cannot read, and another person approves the profile. A dry run shows which papers will be created before any are. A sole practitioner may approve their own profile with a written attestation.

Treat that attestation as a document an inspector may read. A useful one says:

  • that no other suitably experienced person was available to approve the profile;
  • that you checked each fact Achekam read, and those it could not read, against the client's records;
  • why the resulting set of papers fits the engagement's risks;
  • the date, and your name.

One paragraph is enough. "Approved, sole practitioner" is not.

Using the people you already have

Many sole practitioners are not quite alone. There is a bookkeeper, a trainee, or a part-time senior. Put them on the preparer side of the line. When a trainee prepares a working paper, the practitioner can review it; when a senior drafts the materiality proposal with a written rationale, the practitioner as engagement partner can approve it; when someone else is recorded as preparer of the statements, the practitioner can sign them.

That arrangement is not a workaround. It is how review is supposed to run, with the more experienced person checking the less experienced one.

For South African payroll, the rules are firm: the person who prepared a pay run cannot approve it, and nobody can approve a run that pays themselves. A practice running payroll needs two people in payroll roles, which is worth knowing before you accept a payroll client.

Bringing in another firm to review or sign

Where nobody else in the practice can provide the independent look, Achekam lets you borrow one.

A firm can send a frozen set of statements to another firm on Achekam, or to an outside practitioner by an e-mailed link, for an independent review under ISRE 2400 (Revised) or an audit. The reviewer's signed report is bound to that version. An audit report needs a partner whom the listing firm records as an IRBA registered auditor, and Achekam does not check that record with IRBA, so confirm the registration yourself. Independent review by another firm walks through the exchange.

A firm can also have another firm's officer compile its prepared statements under ISRS 4410 (Revised), or act as accounting officer and sign them. The statements are then issued only in the version that officer released. When an external officer signs off covers that route.

Quality review in a one-partner firm

Achekam lets a partner name an engagement quality reviewer, who must be a partner or senior manager not on the engagement team, and who must clear the audit report before it can be issued. For a South African firm, Achekam does not require a reviewer for any engagement type; it is the firm's decision.

In a one-partner practice there may be nobody who fits. The quality management standards anticipate this: a small firm can look outside for an engagement quality reviewer, or use a review before issue by an experienced practitioner from another practice, under an agreement that covers confidentiality and timing. Whatever you choose, write it into your policy so the choice is made once, not under deadline pressure.

IFAC's quality management series on small firm implementation is written for exactly this kind of practice, and helps small and medium practices apply ISQM 1, ISQM 2 and ISA 220 (Revised).

Planning the year around a second person

The real risk for a sole practitioner is not the rule. It is discovering the rule in the last week before a deadline. A few habits remove most of that risk:

  1. At the start of each engagement, list which steps need another person and name that person.
  2. Book outside reviewers and external officers when you accept the engagement, not when the statements are ready.
  3. Freeze statements only when they are final, because a review is bound to the version you send.
  4. Keep attestations and outside-review agreements together in one place, so next year's inspection has one folder to read.
  5. Check payroll and timesheet approvals have a named approver before the first month starts.

Start with your busiest season. Take the engagements due in it, mark every step that needs a second person, and put a name and a date against each one this week.

General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.

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