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What records do I need to keep for ICAEW DPB compliance?

Category: Compliance

The ICAEW DPB Handbook requires firms to maintain comprehensive records of all referral activity that falls under the Designated Professional Body regime. At a minimum, you should keep records of: the referral itself (who was referred, to whom, when, and why), evidence of informed client consent (ideally signed or acknowledged in writing), the fee disclosure provided to the client (including the nature and approximate amount of any commission), any due diligence carried out on the receiving firm, and the outcome of the referral (whether the client proceeded, what product or service was taken up, and any fees received). These records should be kept for at least six years, which aligns with the standard retention period for professional records. Some firms keep them longer as a matter of good practice. During an ICAEW monitoring review, inspectors will typically ask to see a sample of referral files. They will check that consent was obtained before the referral was made, that fee disclosure was specific and timely, and that the firm can demonstrate an audit trail from initial referral through to outcome. Firms that track referrals informally — through emails, spreadsheets, or verbal agreements — often struggle during these reviews. A centralised system that captures consent, disclosure, and outcomes in one place makes it significantly easier to demonstrate compliance. The key principle is straightforward: if you cannot evidence it, you cannot prove you did it.