What a new name actually sets off #
A new client is not one job. It is a sequence, and several of the steps cannot start until an earlier one finishes. In a practice the sequence usually looks something like this, though the detail depends on the services and on your supervisor:
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Establishing who the client is, and who ultimately owns or controls them
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Customer due diligence under the Money Laundering Regulations
Including the risk assessment that decides how much diligence is enough.
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An engagement letter setting out scope, and getting it signed
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Agent authorisation with HMRC for each service you will act on
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Professional clearance where there is an outgoing accountant
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Collecting the opening records
The same chase covered in what chasing clients for records costs.
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Setting the client up in whatever systems the practice runs
The compliance steps are not optional and not light #
HMRC guidance on the Money Laundering Regulations describes customer due diligence in a sentence.
taking steps to identify your customers and checking they are who they say they are
Enhanced due diligence applies in higher risk situations, including customers who are not physically present. The guidance also requires a written policy, a nominated officer, staff training, and records kept for five years beginning from the date a business relationship ends or a transaction is completed.
Supervision itself is a registration obligation. HMRC guidance states that accountancy service providers must register unless they are already supervised by a professional body, and that trading while not registered "is a criminal offence. It may result in a penalty or prosecution". Registration is renewed annually.
For company clients there is now a further layer. Identity verification at Companies House became a legal requirement on 18 November 2025, having been voluntary from 8 April 2025, and it covers directors, people with significant control and authorised corporate service providers.
Whether your practice acts as an ACSP or leaves verification to the client, the status of each director is one more thing a new company engagement has to track. That is covered further in the Companies House page.
Where the hours actually go #
Ask a practice how long onboarding takes and you get an estimate of the working time. Ask how long it takes from first conversation to first piece of chargeable work and the number is several times larger. The gap is where the cost hides, and it breaks down into three kinds of time.
Collecting the same information more than once
A new client typically supplies their details to a website form, again on an identity check, again on an engagement letter, and again when the practice sets them up internally. Nothing in that is judgement. It is the same facts, re-entered, with a fresh opportunity for a typo at each step.
Establishing state
"Where have we got to with the new client" is a question that gets reconstructed by hand, usually by opening an inbox. In a practice taking on a handful of clients a month, that reconstruction happens dozens of times per client across the onboarding period.
Dead waiting
A stalled authorisation or an unsigned letter costs nothing while somebody is watching it and a great deal when nobody is.
Which parts run on rules #
Runs on rules
- Knowing which steps a given engagement requires (the list follows from the service)
- Knowing which steps are done, open or stalled (if status is recorded somewhere single)
- Prompting a client who has not signed or supplied (rules for the trigger)
- Carrying the same facts across forms
Judgement
- Deciding the risk rating of a client (yours to own)
- Deciding whether an explanation is credible (with professional consequences)
- Deciding whether to take the client at all
What this page is not saying #
- That any part of customer due diligence can be delegated to software
- That doing so would satisfy your obligations
The Money Laundering Regulations place the duty on the business, and your supervisor, whether HMRC or a professional body, will hold the practice to it. Anything that touches identity documents or client data also has to satisfy your UK GDPR duties, and the practice has to make that assessment itself.
What is defensible is that the tracking around those decisions, which is most of the elapsed time, is not a judgement problem at all. It is a list, a set of statuses and a set of dates. If you want a number for how much of your week that accounts for, the cost of admin time calculator is a starting point, and the free audit counts it properly.