ACCA's 2026/27 AML annual return asks firms to upload two documents: their firm-wide risk assessment and their AML policies and procedures. We write both from about 20 minutes of questions about your practice with your facts to hand, and give you a sheet of your answers to copy into the return. The same answers are laid out for ICAEW, AAT and HMRC. You check everything and you file it yourself.
£149 + VAT a year. Verify's client checks are £39 + VAT a month if you want them too.
The questionnaire asks who supervises your firm. The sheet has a tab for each supervisor, all read from the same answers, laid out the way that supervisor asks. Where your answers decide a row exactly, the answer is filled in and ready to copy. Where they cannot, the row says “Not held” and says why, so nothing is guessed.
The return is ACCA's own form; these are the parts the pack is built around.
"Please upload the firm's current firm-wide risk assessment" and "Please upload the firm's current AML policy and procedures document", up to five files each.
Whether a proliferation financing risk assessment is documented, whether a written report on the effectiveness of the firm's AML systems and controls has been produced, whether the MLRO has completed formal AML training in the past two years, and whether staff have a formal process to report suspicion to the MLRO.
Client numbers, sectors, overseas links, suspicious activity reports and more, each answered in ACCA's own bands.
The ACCA sheet lists the form's 58 rows in its order and its wording, each with your answer in the form's band where the questionnaire holds it. Your sheet shows the rows that apply to your firm.
Source: ACCA, 2026/27 Anti-Money Laundering (AML) Annual Return — UK (ACCA's published form, PDF). Uploads are on pages 19–20; the controls questions on pages 16–19.
ACCA's FAQs say a firm is supervised by ACCA for AML when one or more ACCA practising certificate holders have combined majority control (more than 50%) of the firm, and that ACCA automatically supervises sole practitioners holding an ACCA practising certificate. If you are unsure, ACCA's AML supervisory team can tell you. This page is for firms that file ACCA's return.
Source: ACCA AML Annual Return FAQs, 2025 edition, pages 2–3. Only ACCA? The ACCA-only page is here.
The same questionnaire, the same documents, a different sheet.
These are the anti-money laundering questions in ICAEW’s annual return (AM01 to AML17), with your answers ready to copy where the interview holds them. The return itself is filed in ICAEW’s own online annual return; it asks for no documents.
Seven of the 13 rows are worded from ICAEW’s guidance notes, not the form, and are marked so.
AAT asks you to have this information to hand before you start its AML annual firm return. Your answers are ready to copy where the interview holds them. AAT’s form does not let you save part-way or amend an answer, so gather every row first.
Each row is worded as AAT’s guidance page lists it; the form may word it differently.
HMRC’s annual declaration has no questionnaire: you check your registration details in your HMRC account, submit the declaration, then pay the fee.
The pack lists the details to check, as the questionnaire and My practice hold them, then the two steps, then what an HMRC officer asks to see: the inspection-ready pack, described below.
Sources: ICAEW annual return guidance notes (1 November 2025); AAT’s AML annual firm return page; HMRC’s guidance on the annual refresh of supervision (ECSH44875) and on what an officer checks (ECSH52800).
The pack gives you seven documents, with your own assessment of each risk in the first, and the return sheets for ACCA, ICAEW, AAT and HMRC. The AML diary and the inspection-ready pack come with Verify today.
See a finished example: the seven documents and the ACCA return sheet for a fictitious practice →
PracticeGuard Shield, coming soon, adds AML training for your team and more, priced at launch.
Your current firm-wide risk assessment, AML policies and training log go in as PDF, Word (.docx) or text files, each into its own box. We read a document once and show what it supports as suggestions — the passage we read, and the answer it would give — which you confirm or reject one by one. Nothing becomes an answer without your confirm; a control is only ever suggested as in place when the document states it, and a document’s silence is never read as evidence.
After an upload, the pack lists where the document no longer matches the rules as they stand. Seven checks, run by code rather than by a model: the term “high-risk third country”, which the regulations no longer use; a threshold stated in euros rather than sterling; no proliferation financing risk assessment in the document; enhanced due diligence triggers in the wording before 30 June 2026; a training log whose latest date is more than 12 months old, or with no readable date; a nominated officer whose name we could not find; the 2020 national risk assessment cited.
Each finding quotes the passage and the page where there is one, and puts a decision to you. It is not a review of the whole document, and the document is yours to change or not.
Upload your client list as a spreadsheet or CSV and we count it: clients, nationalities, countries and services, and PEP, sanctions and enhanced due diligence where the sheet has those columns. The page shows what was counted and the columns it recognised.
We count it by code; no model reads it. We keep the file, as we keep your other uploads, and the counts. The rows, names and contact details are not copied into your answers, logged or sent anywhere, and the documents do not print the counts yet.
Three passages are copied from your own documents for you to decide on: your stated risk appetite, from your risk assessment; your stated approach to enhanced due diligence, and to ongoing monitoring, from your policies. Each is shown with the file and page it came from. You keep it as written, edit it, drop it, or ask for a suggested rewrite.
A suggestion is drafted only when you ask, from the passage, the requirement and your confirmed answers; a fact it cannot know is left as “[Practice to confirm: …]” for you to fill, and nothing is used until you press Adopt. These passages are optional, and the documents do not print them yet.
ACCA's guidance on templates for the firm-wide risk assessment:
“ACCA acknowledges that templates can be useful and using them is not an issue; however, they must be accurately tailored to reflect the unique risks that the firm is exposed to and the specific procedures of the firm to mitigate them.” ACCA, In Practice, July 2024
“A generic assessment that simply reproduces template wording is unlikely to satisfy regulatory expectations.” ACCA, In Practice, June 2026
So the pack asks for your assessment, one risk factor at a time.
The same answers feed the documents and every supervisor's sheet, so they say the same thing.
You can buy it on its own. PracticeGuard Verify's client checks are £39 + VAT a month, with a free first month, if you want them too.
The questionnaire is free. The PDF pack is £149 + VAT a year.
Start the AML return pack