What ACCA's 2026/27 AML annual return asks for
Most of ACCA's 2026/27 AML annual return covers ground you will recognise from earlier years. It then ends with something new: two documents to upload. This page walks through what the form asks, in the form's own words, and what to have ready before you start.
In short
- The form has four parts: firm details, individual details, an AML questionnaire about your firm and its clients, and a section headed AML controls and legal requirements.
- The questionnaire asks for numbers in ACCA's own bands: people, revenue, clients, types of client, overseas links and suspicious activity reports.
- The controls section asks whether your firm-wide risk assessment, your policies, a proliferation financing risk assessment and an MLRO report on effectiveness are documented and kept up to date, and about training, onboarding, monitoring and client risk ratings.
- New this year: you upload your current firm-wide risk assessment and your AML policy and procedures document, up to five files each (pages 19 and 20).
1. Who files it
The return is for firms that ACCA supervises for anti-money laundering. ACCA's FAQs (2025 edition) explain when that is.
Firms are supervised by ACCA for AML supervision when there are one or more ACCA PC holding members with a combined majority control over the firm (i.e., more than 50%).
The same FAQs say “ACCA automatically supervises sole practitioners holding an ACCA PC for AML”. If you are connected with more than one firm, they ask for one return per firm: “Please make sure that a separate return is submitted for each firm that you are associated with.” If you are not sure who supervises your firm, ACCA's AML Supervisory Team can tell you.
2. The questionnaire: your firm and your clients, in bands
Pages 4 to 15 ask about the size and shape of the practice. The counts are bands you pick, not figures you type. In order, the form asks for:
- the number of additional partners, directors, employees and sub-contractors, full and part-time;
- the firm's total revenue for the last financial year, and the number of clients served in the past 12 months;
- approximately how many clients fall into each of thirteen types, including cash-based businesses, high-value dealers, property, import and export, money service businesses, cryptocurrency, visa and immigration services, charities, wealthy individuals and politically exposed persons;
- how many clients represent more than 15% of the firm's revenue, whether any existing client has been convicted of a financial-related crime or appears in a sanctions list, and how many are based outside the UK or have associations with HM Treasury's advisory notice on high-risk third countries;
- suspicious activity reports filed with the NCA, and internal reports escalated to the MLRO, both over the past two years;
- client money, payroll, registered office, trust formation, director or secretary, trustee and company formation services.
Two points from ACCA's FAQs (2025 edition) help with the counts. Count every client, “both regular and one-off clients, for the relevant period”. And a client who owns a UK business or property but usually lives abroad counts as non-UK: “For the purpose of this return - yes.”
Later, on pages 18 and 19, the form asks what share of your clients you classify as high-risk and as low-risk. David Winch, an AML adviser writing in AccountingWEB, warns against reading too much comfort into a low number.
Please don’t assume that reporting a very high proportion of ‘low-risk’ clients will encourage ACCA to leave you alone.
3. The controls section
Pages 16 to 19 are headed AML Controls and Legal Requirements. Four questions use the same three answers: "Yes - and it is updated on a periodic basis", "Yes - I have conducted it once" and "No". They ask whether you have a documented firm-wide risk assessment, documented AML policies and procedures, a documented proliferation financing risk assessment, and a written MLRO report on how well your AML controls work.
As the MLRO, have you conducted and documented a firm-wide risk assessment?
As the MLRO, have you produced a written report on the operation and effectiveness of the firm's AML systems and controls?
Two questions are about training, and both say what does not count.
Have you provided AML training to all relevant employees? (Please note: we do not consider employees reviewing the firm's AML policies and procedures or receiving 'on-the-job' training to be sufficient AML training.)
As the MLRO, have you completed formal AML training within the past two years? (Please note, we do not consider reading articles or publications to be formal AML training.)
The rest of the section asks whether you are registered with the NCA's suspicious activity reporting system, whether staff have a formal way to report suspicion to the MLRO, what you check when you take on a new client, how often you review existing clients, whether you rate clients by risk, and whether someone checks your AML controls independently. On that last point the form adds a note.
Does the firm conduct and document an independent assessment of its AML controls? (Please note: independent does not necessarily mean external. For example, a partner, director, or senior individual who is not the MLRO may conduct the assessment.)
4. The two uploads
The form ends with two upload boxes, each taking up to five files.
Please upload the firm's current firm-wide risk assessment.
Please upload the firm's current AML policy and procedures document.
ACCA describes this as a small change. David Winch quotes Steven Armstrong, ACCA's AML Lead:
The main difference is that ACCA is asking firms to upload a copy of their firm-wide risk assessment and AML policies and procedures. As it is a legal requirement for firms to have these documents in place, this should not be onerous.
Winch's point is about what the documents show once they are in ACCA's hands.
An experienced AML inspector can identify within seconds indicators of weak compliance, including over-reliance on generic wording, outdated references and a failure to tailor the documents to the firm’s particular circumstances.
So the useful question is not whether you have the two documents, but whether they describe your practice as it is today.
5. When it is due, and why it matters
We do not hold a date for the AML return, so we do not give one: check what ACCA has sent you. ACCA's practising certificate renewals page gives a date for the renewal, which is a different submission.
To help us get your renewal processed in time for 2027 please complete it before 11 December 2026.
A practitioner on AccountingWEB lists the AML return, the firm's annual return renewal and the 2027 practising certificate renewal as three separate requests: “ACCA sent separate emails requiring completion and submission of the following:”
ACCA's FAQs (2025 edition) say what can follow if the return is not done: “Failure to complete the return may result in your Practising Certificate not being renewed.” That describes an earlier edition; read ACCA's current pages for this year's position.
6. What to have ready
| Have ready | Where the form asks |
|---|---|
| Headcount, last year's revenue and the number of clients served in the past 12 months | Pages 4 and 5 |
| Client counts by type, overseas clients, and clients over 15% of revenue | Pages 6 to 12 |
| Suspicious activity reports to the NCA and internal reports to the MLRO, past two years | Page 12 |
| The services you offer: client money, payroll, registered office, trust and company services | Pages 12 to 15 |
| Your firm-wide risk assessment and proliferation financing assessment, and whether you update them periodically | Pages 16, 17 and 19 |
| Your AML policies and procedures, and your MLRO's report on effectiveness | Pages 16, 17 and 20 |
| Training dates for your staff and for the MLRO's own formal training | Pages 16 and 17 |
| Your onboarding checks, monitoring cycle and the share of clients you rate high and low risk | Pages 18 and 19 |
Winch's last point is the one that holds the rest together:
Whether there is evidence supporting the answers which will be entered on the return.
How PracticeGuard helps
PracticeGuard's AML return pack asks about 20 minutes of questions about your practice, with your facts to hand, and writes seven documents from your answers. The first two are the ones this form asks you to upload: the firm-wide risk assessment, with its own proliferation financing section, and your AML policies, controls and procedures. A sheet lists the form's rows in its order, with your answer in ACCA's band where the interview holds it, and "Not held" with the reason where it does not. You check everything and you file the return yourself; we do not file it for you.
Questions people ask
Will ACCA read the documents I upload?
The form does not say. David Winch, writing in AccountingWEB, puts it this way: “To be clear, neither the form nor ACCA's comments indicate that every uploaded document will be subjected to detailed review.” ACCA’s FAQs (2025 edition) say the information in the return “will be corroborated during the firm’s AML review where documentary evidence will be expected”.
I am a sole practitioner. Do I still need a firm-wide risk assessment and policies?
Yes. ACCA’s FAQs (2025 edition, page 6) say: “All firms, including sole practitioners, must have a documented firm-wide risk assessment.” They say the same of documented AML policies and procedures. Our guide to the firm-wide risk assessment covers what goes in one.
When is the return due?
We do not hold a date for the AML return, so we do not give one: check what ACCA has sent you. The date on ACCA’s practising certificate renewals page is for the renewal, which is a separate submission.
What counts as AML training for the return?
Not on-the-job training or reading your policies. ACCA’s FAQs (2025 edition, page 6) say: “‘On the job training’ (e.g., providing feedback and reviewing work), reading policies and procedures and regular meetings are not considered AML training.” Our guide to AML training records covers what ACCA expects instead.
Who do I ask about a question on the form?
ACCA’s FAQs (2025 edition, page 7) name its AML Supervisory Team for questions about the form, and its Technical Advisory Team for advice on putting controls in place.
Sources
- ACCA, 2026/27 Anti-Money Laundering (AML) Annual Return - UKThe published form, 20 pages · ACCA
- ACCA, AML Annual Return FAQs2025 edition · ACCA
- ACCA, Practising certificate and licensing renewalsRead 30 October 2026 · ACCA
- David Winch (MLRO Support), "The latest ACCA AML return: A sting in the tail?"AccountingWEB, 14 October 2026 · AccountingWEB
- AccountingWEB Any Answers, "ACCA 2026/27 AML Return and Practice Renewal"A practitioner thread, October 2026 · AccountingWEB
PracticeGuard supports your judgement; it never replaces it. This page describes what the Money Laundering Regulations 2017, the accountancy sector guidance and the supervisors’ own published documents say, with the source for each point, so you can read it yourself. It is not legal advice, and nothing here is advice about what your supervisor will accept. PracticeGuard is not affiliated with or endorsed by ACCA, ICAEW, AAT, HMRC or any AML supervisor. Check the current version of each document before you rely on it.
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