Short answer: before you sign with an offshore accounting provider, find out who will actually do the work and how it is reviewed, whether they will sign a UK GDPR Article 28 contract and a valid transfer mechanism, how they handle HMRC access, what your AML supervisor and PI insurer need to know, and what it costs to leave. A provider worth using answers all ten questions below in writing, without needing to be chased.

Most practices pick an offshore provider on price and a good first call. The problems show up three months later: a different person on every file, a contract that says nothing about deleting your data, or an insurer who was never told. None of those are hard to check. They just aren’t the questions a sales call tends to cover.

We get asked these questions by UK practices every week, and we think every provider, including us, should be held to them. If you haven’t yet decided what to outsource, start with what to hand over first. If you are still weighing offshore against a UK provider, see in-house vs UK outsourcing vs offshore.

Do your own homework first

Two things sit with your practice whichever provider you choose.

Your engagement letters and privacy notice. Client confidentiality is your duty under the ICAEW and ACCA codes, and it doesn’t pass to the provider. Check that your engagement letter allows work to be subcontracted, including outside the UK, and that your privacy notice lists subcontractors among the people who receive client data. Clients don’t need the provider’s name. They need to have agreed to the arrangement.

Your own data map. List what the provider will see: bank statements, payroll records, director details, National Insurance numbers. That list decides how strong the contract and security answers need to be.

The 10 questions

1

Who exactly will work on our files, and what are their qualifications?

Ask for the names, roles and qualifications of the people who will do your work, not the firm’s headcount. Then ask whether they will be the same people next month. A named team learns your clients. A rotating pool relearns them on every file, and that cost lands on your reviewers. We set out the difference in dedicated team vs ticketing.

2

Will you work in our software, with your own logins?

The answer you want is yes on both. Work done inside your Xero, QuickBooks, Sage, IRIS or BrightPay stays in your audit trail, and named users with multi-factor authentication mean every entry has a person attached and access can be removed in minutes. Be wary of a provider who wants client data exported to their own systems, or who asks to share one login across a team.

3

Will you sign a UK GDPR Article 28 contract, and who are your sub-processors?

Your practice is the controller and the provider is your processor. UK GDPR requires a written contract covering instructions, confidentiality, security, deletion at the end and audit rights. It also says a processor must not bring in a sub-processor without your prior written authorisation (ICO: what needs to be included in the contract). Ask for their draft agreement before the second call. If they have to go away and write one, they haven’t done this before.

4

What transfer mechanism covers our data?

Personal data accessed from outside the UK is a restricted transfer. India is not on the UK’s adequacy list, so the arrangement needs an appropriate safeguard, usually the ICO’s International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses, with a transfer risk assessment on file (ICO: international transfers). A provider should name the mechanism without having to look it up.

5

How is work reviewed before it reaches us?

Ask who reviews each file, at what level, and what a review leaves behind. A second qualified person checking the working papers is very different from the preparer checking their own output. Ask to see a sample review checklist. Your own review stays, at least in the early months, but a provider’s first-level review decides how much of your reviewer’s time the arrangement saves.

6

How do you handle HMRC access?

The right answer is that they never ask for your HMRC sign-in details. HMRC prohibits sharing them for any purpose (GOV.UK: use of HMRC sign-in details). The common split is that the provider prepares the return in your software and your practice reviews and files it. Where a provider does submit, it should be on your written instruction and by a route that doesn’t involve your credentials.

7

How will this fit our anti-money laundering procedures?

ICAEW’s guidance is direct: all the money laundering responsibilities for subcontracted work remain with your firm. It recommends making the subcontractor contractually bound to your procedures, giving them AML training and including them in your staff screening (ICAEW: using a subcontractor). Ask the provider how they report a suspicion to your MLRO. If they look puzzled, that is your answer.

8

What does our PI insurer need to know?

The same ICAEW helpsheet notes that for the anti-subrogation clause of your professional indemnity policy to extend to a subcontractor, their name and status have to be given to your insurer. Tell your broker before work starts, not at renewal. Some insurers add conditions for offshore work, and it is far better to know those up front.

9

What is the full cost, and what is the notice period?

The hourly rate is the least interesting number. Ask about onboarding fees, minimum hours or minimum terms, whether complex work is charged at a higher rate, how hours are recorded, and how much notice either side has to give. Ask for a timesheet sample. A twelve-month minimum term makes sense for the provider. It rarely makes sense for a practice that is still testing the arrangement. For typical numbers, see what accounting outsourcing costs in the UK.

10

What happens to our data and working papers when we leave?

Article 28 requires the contract to cover deleting or returning personal data at the end. Ask how that is done, how quickly, and how you get confirmation in writing. Because the work lives in your software, leaving should mean removing a few users rather than recovering files. If leaving would mean a data migration, think again before you start.

Good answers and red flags

QuestionGood answerRed flag
Who does the workNamed people, qualifications stated, the same team each month“A pool of experienced accountants”
Software accessYour software, named users, multi-factor authenticationA shared login or an export to their systems
Data contractArticle 28 agreement sent before you ask“We’re fully GDPR compliant” with nothing in writing
TransfersNames the IDTA or the UK Addendum“India has adequacy” (it doesn’t)
ReviewA second qualified reviewer, with a checklist you can seeThe preparer checks their own work
HMRCNever asks for your sign-in detailsAsks for your Government Gateway login
ExitShort notice, written confirmation of deletionLong minimum term, data held in their systems
A paid trial tells you more than references do

References tell you a provider has happy clients. They don’t tell you how the provider handles your clients. Two or three weeks of real work on simple, complete files will show you turnaround, review quality and how many questions come back. Our first-month checklist sets out how to run it and what to measure.

Three mistakes practices make when choosing

Choosing on the hourly rate. A provider charging £2 an hour less who needs twice the review time costs you more. The hours your senior reviewer spends correcting work are the most expensive hours in the arrangement.

Treating the contract as a formality. The data agreement is where you find out whether the provider has thought about sub-processors, breaches and exit. A thin contract usually reflects thin processes.

Forgetting the people outside the deal. Your MLRO, your PI broker and whoever maintains your engagement letters all need to know before the first file moves. Bringing them in afterwards is much harder.

How EarthOne answers these questions

Qualified Indian Chartered Accountants work inside your own software from their own named logins. A second CA reviews every file before it comes back to you, and weekly timesheets show who did what. We sign a UK GDPR Data Processing Agreement before the first file moves, and nothing goes to HMRC without your instruction: we submit on your instruction, or hand the return back for you to review and file. Ad hoc work is £10.50 to £16.50 an hour, or a dedicated bookkeeper or accountant from £750 a month, with no onboarding fee and one month’s notice. See offshore accounting services for UK firms or published pricing.

Put these ten questions to us

Send us the work you want to outsource, your software and roughly how many clients. We reply within one business day with written answers, our draft Data Processing Agreement and the cost.

Send an enquiry

Frequently Asked Questions

What should a UK practice ask an offshore accounting provider before signing?
Who will do the work and how it is reviewed, whether they work in your software with named logins, whether they will sign a UK GDPR Article 28 contract, which transfer mechanism applies, how HMRC access is handled, how they fit your AML procedures, what your PI insurer needs to know, the full cost and notice period, and what happens to your data when you leave.
Is India covered by UK data adequacy regulations?
No. India is not on the UK adequacy list, so personal data accessed from India needs an appropriate safeguard, usually the ICO's International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses, backed by a transfer risk assessment.
Do we need client consent to use an offshore provider?
Your engagement letter should allow work to be subcontracted, including outside the UK, and your privacy notice should list subcontractors as recipients of client data. Confidentiality stays your duty under the ICAEW and ACCA codes. Clients do not need to know the provider's name.
Do we need to tell our professional indemnity insurer?
Yes, before work starts. ICAEW guidance notes that a subcontractor's name and status must be given to your PI insurer for the anti-subrogation clause of the policy to extend to them. Some insurers attach conditions to offshore work.
Who is responsible for anti-money laundering on outsourced work?
Your firm. ICAEW guidance says all money laundering responsibilities for subcontracted work remain with the firm, which should bind the subcontractor to its procedures, train them and include them in staff screening.
Can an offshore provider use our HMRC sign-in details?
No. HMRC prohibits sharing its sign-in details for any purpose. The provider should prepare the work in your software. Your practice files it, or the provider submits only on your written instruction by a route that does not use your credentials.
Should the provider work in our software or theirs?
Yours. Working inside your own Xero, QuickBooks, Sage, IRIS or BrightPay with named users and multi-factor authentication keeps the audit trail with you and lets you remove access in minutes.
How should we test a provider before committing?
Run a paid trial of two to three weeks on simple clients with complete records. Measure turnaround, review points per file and questions per job before adding more work.

Ketul Patel, Founder - EarthOne Accounting LLP

Chartered Accountant with over 10 years of experience across MSME accounting, finance staffing, training and leadership hiring. Founder of the AccountingBaba Group and EarthOne Accounting LLP, which provides qualified CA support to UK accounting firms and businesses at published pricing on one month's notice.