Accounting firm: how to choose a provider and what to check before signing

    Status, qualifications, liability, confidentiality and handover — criteria that only show up later

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    An accounting firm is an organisation to which a company's head delegates bookkeeping under a contract. The law names such organisations explicitly: audit firms, tax consultancy firms and other organisations whose charter provides for bookkeeping services (Article 11 of the Law «On Accounting»). It is worth choosing on four criteria: the team's qualifications, a contract with clear liability, data protection and the handover procedure.

    Delegating the books does not relieve the head of the company of the duty to ensure complete and reliable accounting and the safekeeping of documents (Article 11 of the Law), and the taxpayer company itself is responsible for the accuracy of its tax returns (Article 81 of the Tax Code). Choosing a provider is therefore a decision about risk, not just about price.

    When a business needs an accounting firm

    • A new company: a new legal entity determines its tax accounting methods during its first reporting period (Article 77 of the Tax Code) — it is convenient to set them up together with the provider from the outset.
    • The in-house accountant has left or the books have been neglected.
    • Volume and risks are growing: switching to VAT, employees, imports, several types of activity.
    • The company is subject to mandatory audit, and the books must be kept by a specialist meeting the requirements of Article 12 of the Law.
    • The owner cannot assess the accountant's work and wants external control.

    Selection criteria

    • Status: bookkeeping is provided for in the provider's charter (Article 11 of the Law).
    • Qualifications: if your company is subject to mandatory audit, the provider's specialist must have higher education and at least 3 out of the last 5 years of experience with an economics degree, or 7 out of 10 with a non-economics degree, and must complete annual professional development (Article 12 of the Law).
    • A team, not one person: who keeps the books, who reviews, who covers during holidays.
    • Experience with your tax regime and industry: VAT, imports, manufacturing, construction, trade.
    • Knowledge of the 2026 changes: some tax returns are now generated by the tax authority, and five days are given to correct them, but no later than the filing deadline (Article 81 of the Tax Code).
    • Deadline calendar: the provider should name your dates — the 15th and 20th of each month, and 15 February and 1 March for the year — and show how it monitors them (Articles 273, 339, 389, 407, 470 of the Tax Code).
    • A clear procedure: deadlines for handing over documents, communication channels, a monthly report to management.

    Contract and liability

    Breaches of accounting legislation — for example, unreliable accounting and reporting data or failure to carry out an inventory count — are punishable by fines on officers: 3–7 BCV, and 7–10 BCV for a repeat breach within a year (Article 175¹ of the Code of Administrative Responsibility). A contract with the provider does not change this, so it is important to set out how the consequences of errors are allocated:

    • the scope of work itemised, and what is charged separately;
    • deadlines: when the client hands over documents and when the provider files the returns;
    • reimbursement of fines and penalty interest arising through the provider's fault;
    • who signs the returns: tax returns — the taxpayer or an authorised representative with a document confirming authority (Article 82 of the Tax Code); financial statements — the head and the person keeping the books, or the chief accountant (clause 4 of Regulation reg. No. 3567);
    • signing authority for primary documents: the head approves two lists of persons authorised to sign, and documents without their signatures are invalid (Article 13 of the Law).

    Confidentiality and access

    Persons who have access to accounting registers must keep them confidential, and registers may be reviewed with the permission of the head or in cases provided for by law (Article 28 of the Law). In practice this is supplemented by a non-disclosure agreement and a list of the provider's staff who have access.

    Access to the bank, the accounting database and the taxpayer's personal account is granted by role; the head's e-signature key is not handed over unless necessary, and access is revoked when the contract ends.

    Handover: on entry and on exit

    • On entry — acceptance under a handover certificate: account balances, the status of periods, returns already filed and reconciliation with data in the personal account. The certificate records the state from which the provider becomes responsible for the books.
    • On exit — the accounting database in working order, registers, and an archive of primary documents and returns under an inventory list.
    • Retention periods: primary documents, registers and financial statements — at least five years after the reporting year (Article 29 of the Law); tax accounting records — until the three-year limitation period expires (Articles 79, 88 of the Tax Code); tax returns — at least three years after the year of filing (Article 84 of the Tax Code). Where the archive is kept is specified in the contract.
    • The handover is planned before the next reporting date so as not to miss the 15th and 20th deadlines.

    An audit firm acting as the accounting firm

    Audit firms may keep books and prepare financial statements as a related service (Article 33 of ZRU-677). But if they did so in the period under audit, they are prohibited from auditing that client (Article 34 of ZRU-677). A company subject to mandatory audit chooses its auditor separately and in advance.

    Red flags

    • no written contract, or the scope of work is not stated in it;
    • promises of «optimisation» through documents without real transactions, or «zero» taxes;
    • suggestions to show VAT on invoices without VAT payer status — this means a fine of 20% of the VAT amount plus payment of that amount to the budget (Article 225 of the Tax Code);
    • inability to explain who signs the returns and on what basis;
    • requests for the e-signature key and passwords before the contract is signed;
    • unwillingness to describe how the database and archive are handed over on termination;
    • one accountant for all clients with no cover.

    How to vet a provider before signing

    The quality of bookkeeping often shows only during a tax inspection, when it is too late to change anything. It is safer to see how the provider works before signing:

    • Describe your business — tax regime, documents per month, employees, foreign trade — and ask several providers for a proposal with the scope of work and procedures.
    • Ask for a sample monthly management report: which taxes, deadlines and risks it shows.
    • Ask practical questions: how the provider checks returns generated by the tax authority, how it tracks the UZS 1 billion threshold for turnover tax (Article 462(7) of the Tax Code), and who responds to notices from the tax authority.
    • Meet the person who will actually keep your books, not just the account manager.
    • Start with a diagnostic review of your current accounting with a written result — it shows both the state of your documents and the provider's level.

    Cost and deliverables

    The price depends on document flow, tax regime, number of employees, foreign trade and the state of the books, and is fixed in the contract after the diagnostic review. What you receive: returns filed on time, an up-to-date accounting database, a document archive and a monthly summary of taxes and risks.

    Discuss accounting services

    We will show you the scope of work, procedures, the team and a draft contract before you sign.

    Go to the «Accounting services» page

    Frequently asked questions

    Which organisations may keep books under a contract?

    Audit firms, tax consultancy firms and other organisations whose charter provides for bookkeeping services (Article 11 of the Law «On Accounting»). The head of the company may also engage an accountant under a contract or keep the books personally.

    Who is responsible for an accounting firm's errors?

    Towards the state — the company itself and its officers: the taxpayer is responsible for the accuracy of tax returns (Article 81 of the Tax Code), and officers are fined for breaches of accounting legislation (Article 175¹ of the Code of Administrative Responsibility). How losses from the provider's errors are compensated is governed by the contract, so a clause on reimbursement of fines and penalty interest should be agreed in advance.

    Can an accounting firm file returns on our behalf?

    Yes, with authority properly documented: the return is signed by the taxpayer or its authorised representative, and a copy of the document confirming authority is attached (Article 82 of the Tax Code). A tax consultancy firm may file returns electronically on the taxpayer's behalf through the taxpayer's personal account.

    Does an accounting firm need a licence?

    The Law «On Accounting» sets the criterion not as a licence but as the charter: books are kept under contract by organisations whose charter provides for such a service (Article 11). If your company is subject to mandatory audit, also check the specialist's qualifications under Article 12.

    Can the same firm keep our books and audit us?

    Not for the same period: an audit firm is prohibited from auditing a client for which, in the period under audit, it set up, kept or restored the books or prepared financial statements (Article 34 of ZRU-677).

    What should we take back when changing accounting firms?

    The accounting database in working order, registers, primary documents and returns under an inventory list — and revoke all access. Accounting documents are kept for at least five years after the reporting year (Article 29 of the Law «On Accounting»).

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