First impressions suggest that identifying the Irish companies required to comply with the CSRD will be a straightforward process, but first impressions can be deceptive, writes Fiona Hackett The European Union (EU)’s Corporate Sustainability Reporting Directive (CSRD) was published in its Official Journal in December 2022.   The CSRD replaces the Non-Financial Reporting Directive (NFRD), which in Ireland was applied by companies with more than 500 employees that are public limited companies or regulated by the Central Bank of Ireland. The Irish Government is currently working on the amendments to the Companies Act 2014 that will enact the requirements of the CSRD in Ireland. It is required that these amendments be reflected in Irish law by 6 July 2024. GAAP for sustainability reporting Once enacted in Ireland, the CSRD will require a significant number of Irish companies to prepare a sustainability report subject to assurance by a third party. The sustainability report will need to comply with the suite of 12 European Sustainability Reporting Standards (ESRSs) issued by the European Financial Reporting Advisory Group (EFRAG). These 12 ESRSs have been directly written into EU law and are effectively GAAP for sustainability reporting, covering general sustainability requirements and topical matters under the ‘E’ (Environmental), ‘S’ (Social) and ‘G’ (Governance) pillars.   The ESRSs run to over 350 pages and EFRAG has estimated that there are over 1,000 quantitative and qualitative data points necessary to comply with the more than 80 disclosure requirements of the ESRSs. The CSRD and companies in Ireland The EU has estimated that the number of companies across the EU that will apply CSRD requirements is about 50,000 as opposed to the roughly 11,000 companies that apply NFRD – almost a five-fold increase. However, I would argue that due to the large number of Irish special purposes vehicles, the large population of Irish regulated entities and the popularity of Ireland as the location for intermediate holding companies in large multinational groups, there will be a greater than five-fold increase in the number of companies impacted by the CSRD in Ireland compared with those complying with the NFRD. First impressions of the CSRD suggest that identifying the Irish companies that will be required to prepare a sustainability report and comply with ESRSs is straightforward.   At its simplest, for financial years starting on or after 1 January 2025, large companies, for the purposes of the Companies Act 2014, will be required to prepare a sustainability report that complies with the ESRSs (with some of our large listed companies reporting from 1 January 2024).  We all know that first impressions can often be misleading, however. Identification of what entities will be required to prepare a sustainability report and comply with the ESRSs requires careful consideration and analysis of the type of entity, and – if the entity is a subsidiary company – how the group structure impacts on the preparation of a sustainability report that complies with the ESRSs. Why is type of entity relevant? At present, the Irish enactment of the CSRD is focusing on companies incorporated under the Companies Act 2014.   The Department of Enterprise, Trade and Employment (DETE) indicated in a July webinar that it intends to exempt credit unions and friendly societies from the requirements of CSRD.   Future developments in sustainability reporting and later government policy decisions may see such entities, not subject to the Companies Act 2014, required to prepare sustainability reports that comply with the ESRSs.  The DETE webinar also indicated that not-for-profit companies (often incorporated as companies limited by guarantee) are not in scope of CSRD. They may consider voluntary adoption of the requirements, however.   What should subsidiaries consider? For companies that are subsidiaries, the wider group impact of the CSRD needs to be considered and understood. Whether the subsidiary has a parent in the EU or outside the EU will be crucial in determining the level of sustainability reporting required by the subsidiary. For a large company that is a subsidiary of an EU parent company, it is likely that the EU parent company will be required to prepare a consolidated sustainability report that complies with the ESRSs.   This consolidated sustainability report of the EU parent should include the activities of the Irish subsidiary. It is likely the Irish company will be required to report sustainability information to its parent for inclusion in the consolidated sustainability report.   Such an Irish subsidiary, included in the consolidated sustainability report of an EU parent that complies with the ESRSs, will likely be able to avail of an exemption from preparing its own sustainability report, unless it has debt or equity listed on an EU regulated market. This will be a welcome relief for such companies. On the other hand, in the case of a large company that is a subsidiary of a non-EU parent company, the non-EU parent company is very unlikely to be preparing a consolidated sustainability report that includes the Irish company and complies with the ESRSs.  The large subsidiary company will, therefore, be required to prepare its own sustainability report and comply with the ESRSs in this report.   If this large subsidiary of a non-EU parent company has its own subsidiaries, its sustainability report will be a consolidated report for the group of companies it controls.   It is important to understand that the exemption regime for preparing consolidated financial statements differs from the exemption regime for preparing consolidated sustainability reports.   In Ireland, I expect we will see many intermediate parent companies that have never prepared consolidated financial statements – such as intermediate holding companies that are ultimately subsidiaries of parents in the UK or US – being required to prepare consolidated sustainability reports that comply with the ESRSs when the CSRD becomes effective.   The preparation of a sustainability report that complies with the ESRSs is a significant challenge for a single entity, a bigger challenge for a group of companies and, arguably, an even bigger challenge for an intermediate parent company that has previously never prepared consolidated financial statements, and which does not have an established system or procedures of gathering information for consolidation purposes. Independent exemption regime The exemption regime for companies with respect to preparing a sustainability report that complies with the ESRSs operates independently of the exemption regime for preparing consolidated financial statements.   This appears to be a conscious policy decision made by the EU in developing the CSRD and has been acknowledged in paragraph 26 of the preamble to the CSRD which states: “It should be specified, however, that the exemption regime for consolidated financial statements and consolidated management reports operates independently from the exemption regime for consolidated sustainability reporting. An undertaking can therefore be exempted from consolidated financial reporting requirements but not from consolidated sustainability reporting requirements where its ultimate parent undertaking prepares consolidated financial statements and consolidated management reports in accordance with Union law, or in accordance with equivalent requirements if the undertaking is established in a third country, but does not carry out consolidated sustainability reporting in accordance with Union law, or in accordance with equivalent requirements if the undertaking is established in a third country.” I believe this policy decision demonstrates the importance the EU has placed on sustainability reporting, and both its efforts to be at the forefront of top-quality sustainability reporting and expectation that sustainability reporting will play its part in helping users of annual reports evaluate the sustainability performance of EU companies. The policy decision is also an example of how the CSRD forms part of the European green deal. What action should companies now take? For some Irish companies, there won’t be a lot of complexity involved in understanding whether they are required to prepare a sustainability report that complies with the ESRSs.   We know that an Irish company that has debt or equity listed on the main market of Euronext Dublin and more than 500 employees will have to prepare a sustainability report that complies with the ESRSs for financial years beginning on or after 1 January 2024.   We also know that a large Irish private company that is a standalone company or the ultimate parent company of a large group will be required to prepare a sustainability report that complies with the ESRSs for financial years beginning on or after 1 January 2025.   On the other hand, we also know that a small or medium Irish company will not be required to prepare a sustainability report that complies with the ESRSs while it remains small or medium.  For other Irish companies, the impact of the CSRD is perhaps not as clear-cut. These companies should discuss the requirements of the CSRD with their professional advisors and auditors.   If an Irish company is part of a large multinational group, that company should engage with other parts of the group to understand what work is being done in relation to the adoption of the CSRD and whether there will be exemptions available to the Irish company. Fiona Hackett is Director of Corporate Reporting Services at PwC Ireland and Chair of Chartered Accountants Ireland’s Financial Reporting Technical Committee

It is hard to see how the EU can become a major global player without embracing the reform that would lead to greater integration, says Judy Dempsey The European Union is not in good shape.  There is no agreement over migration or refugees, two issues raised more than two decades ago. The longer member states delay reforming the entire migration and asylum system, the greater the opportunity for anti-immigration and xenophobic parties to capitalise on these delays.  Current trends show that support for the far-right in France, Germany and Poland is increasing in the polls. Instead of co-opting some far-right policies, mainstream parties across Europe need to confront their rising prominence sooner rather than later.  Then there is the unending dispute over how to tackle climate change. This is linked to a radical overhaul of the energy infrastructure across the EU.  Germany and France are at loggerheads about the future of nuclear energy. Germany’s Green coalition party wants to end nuclear energy once and for all, while Berlin has plans to subsidise industry, both of which will delay the country’s transition to renewable energy.  France wants to expand nuclear power for environmental reasons, and Poland is grappling with its coal industry.  Other countries are making the costly and challenging transition to renewable energy sources. This is just the tip of the iceberg.  Eurozone countries cannot agree on further integration of the capital markets and banking system to deepen economic integration.  Take a look at the conflict between the EU Commission and Poland, Hungary and Slovakia. In September, these countries banned Ukrainian grain imports to Europe, going against the European Commission’s authority over trade matters.  As a result, it appears that Member States now hold more power than the commission itself.  It is difficult to see how the EU can become a major global player without embracing the reform that would lead to greater integration – or, at the very least, a bloc that will be more manageable when it expands to incorporate Moldova, Ukraine and the Western Balkans. Enlargement, Russia’s war against Ukraine, the uncertainty of the transatlantic relationship, the results of the 2024 US presidential election, and the rising power of China are all issues that affect Europe’s future.  A new Franco-German paper, put together by a working group of experts and released on 19 September, proposes ideas for making the EU more manageable and governable against a backdrop of pessimism. Based on the premise that there is no agreement on changing the EU treaty – which requires unanimity and, in most cases, a vote from the national parliaments (remember the Nice Treaty vote?) – the paper proposes the following: First, that a coalition of countries move ahead with a “supplementary reform treaty” and, second, that the EU be reorganised around four concentric circles consisting of: the inner circle (presumably eurozone countries);  the rest of the EU;  associate members (Ukraine, Moldova and the Western Balkans); and  the European Political Community (a loose association of European leaders that meet regularly). Given the current state of the Franco-German relationship and its impact on EU integration, it seems unlikely that this paper will be accepted.  Additionally, there are concerns about the democratic legitimacy of the EU and the accountability of its institutions. While the EU parliament has gained some influence, many citizens feel disconnected from the process.  In the face of continued uncertainty, now is the time for smaller and medium-sized countries to propose their plans for the future functioning and sustainability of the EU. Judy Dempsey is a Non-Resident Senior Fellow at Carnegie Europe and Editor-in-Chief of Strategic Europe

The launch of CleverCards marks the latest chapter in Kealan Lennon’s entrepreneurial story and the FCA has ambitious plans for his latest venture It was while taking part in an IDA Ireland trade mission to China in 2019 that Kealan Lennon hit upon the first spark of an idea for CleverCards, the payments platform provider that would, four years later, bring to market what the serial entrepreneur calls “Ireland’s first tax-free digital Mastercard”. “It all goes back to that trip because that’s when I noticed that no one around me was using plastic cards to pay for anything,” Lennon explains. “People in shops and restaurants were using their mobile phones to pay wherever I went and, at the same time, I could see neobank players like Revolut, N26 and Starling starting to gain traction in Europe. The shift was obvious, but the main focus was the consumer market.” Lennon saw a gap in the market for a payment processor that would focus on businesses rather than consumers and set about developing the technology that would underpin the CleverCards platform. “We agreed a partnership with Mastercard pretty much right at the beginning; becoming a payment processor is effectively the foundation of the entire business,” Lennon says. “For a small company trying to integrate with one of the world’s biggest financial service providers – it was a very tall order. We worked with Mastercard in Ireland, then London and Belgium. It took three years.”  CleverCards launched its first product – a digital prepaid employee gift card – just over a year ago on the back of the Small Benefit Exemption introduced by the Irish Government in 2022.  This exemption allows employers to give their employees up to two small benefits each year, tax-free but capped at €1,000 overall. These benefits cannot be made in cash, nor can they be redeemed for cash. They can only be used to purchase goods or services. “It amazes me how few employers actually know about this benefit,” says Lennon. “It’s frustrating. The Government brought this in, and people just don’t know about it.” Cue CleverCards: “We’re the only game in town here. Employers can order our gift cards online on clevercards.com and email it out to their employees loaded with credit of up to €1,000 tax-free,” says Lennon. Employees can, meanwhile, use CleverCards to pay for goods or services anywhere online or in-store using Google or Apple Pay contactless technology. “They can use the cards for cost-of-living expenses and they can use them in small shops and restaurants the length and breadth of the country, whereas traditional plastic gift cards are restricted to a limited selection of retail networks.” Business strategy So far, CleverCards has signed up over 5,000 businesses and 250,000 cardholders. The company generates revenues via a Mastercard fee on all transactions and also charges clients a small handling fee.  Lennon’s ambitions for the business stretch far beyond employee gift cards and the Irish market, however. “Right now, our focus is Ireland but also the UK. We’ve seen pretty rapid growth and we’re expecting to do significantly more business in the run-up to Christmas,” he says. “Looking ahead 18 months, our goal is that every employee in Ireland and the UK has one of our digital Mastercards on their phone.” In the New Year, Lennon also plans to launch CleverCards’ second product – a digital Mastercard for employee expenses. “We want to start expanding further into Europe from late 2024 and, ideally, we want our existing multinational clients in Ireland and the UK to carry us into new territories by recommending CleverCards to other offices in their European network,” says Lennon. “It’s much faster and more cost-effective than spending millions on marketing in each new market. You’re letting your existing customers bring you there instead.  “That’s our strategy and our USP is that our digital cards can be used for all sorts of expenditure, they give control to the financial controller who has visibility of where spend is going, and transactions are automatically authorised because we are the payment processor.”  Early career Lennon’s confidence in CleverCards’ potential is drawn from a longstanding career in entrepreneurship and a seemingly insatiable desire to identify a gap in the market and run with it. Originally from Leixlip in Co. Kildare, the FCA has had an “eye out for opportunities” almost from the very beginning of his working life as a Chartered Accountant. Lennon initially qualified with Simpson Xavier and worked in corporate finance before leaving the firm in 1992 to strike out on his own. “I took the commencement route to becoming a Chartered Accountant. My first choice on my CAO form was commerce, but I missed it by one point and I couldn’t wait around,” he says.  “I was lucky that I started my career under the leadership of Anthuan Xavier at a very entrepreneurial firm. Being able to get in front of clients straight away was a buzz for me.” Lennon decided to leave the firm aged just 23, however, so he could set up his own financial consultancy, offering corporate finance, tax and accountancy advisory services. “I took an office with a big brass sign on the door and I landed my first client, quite honestly I’d say simply because I was a one-man show so I was cheaper than any of the bigger firms,” he says. “That client owned Kartoncraft, a pharmaceutical packaging business, and he had an offer on the table to sell his business to Inistech, an Irish plc at the time. He hired me to manage due diligence.  “The guy they had hired on the corporate finance side was also a one-man show. Once I had a full understanding of his selling price, I said to the client one evening ‘don’t take this the wrong way, but I think your business could sell for a lot more’. “I got the whole textbook explanation of ‘well, it’s an x percent discount on PE multiples and so on’, but he listened to my advice and came back having doubled the price of the business. He fired his corporate finance advisor and hired me instead.  “The Government and IDA Ireland at the time were focused on bringing more pharmaceuticals into the country. I looked at this strategy, put a five-year plan together for my client and, about six weeks later, we went back to the plc and we doubled the selling price again.  “My client made four times his asking price from the time I started working with him. He paid me £100,000. I was able to buy my first house for cash at just 23 and I had a red BMW. I really thought I’d made it.” Kartoncraft and MeadWestvaco But more was to come for Lennon, who was subsequently asked by Inistech to join the board of the newly acquired Kartoncraft in the role of Finance Director. Within 18 months, aged just 25, Lennon had led the management buy-out of Kartoncraft from Inishtech Plc, backed by AIB in Ireland and Dresdner Kleinwort Benson, a London-based private equity house.  He sold Kartoncraft five years later for $20 million to the NYSE-listed MeadWestvaco and joined the US packaging company’s Board of Directors as Head of Mergers and Acquisitions for Europe. “I was the youngest board director of MeadWestvaco Europe, which had 35,000 employees worldwide,” Lennon says. “It’s interesting now to see the media reports about MeadWestvaco and Smurfit Kappa merging, because when I sold Kartoncraft, Smurfit was the underbidder. “It’s quite a ‘full circle’ feeling to see them coming together to become the biggest packaging group in the world, and those early connections are still part of my life today. Both Michael and Tony Smurfit are investors in CleverCards all these years later.” By the time he left MeadWestvaco in 2007 to set up investment firm K Partners, Lennon was ready for a new challenge. “That corporate role was kind of like an on-the-job MBA. I learned so much about strategic development, people management, motivation and incentivisation. “It gave me an incredible insight into how large corporates work, but, deep down, I am an entrepreneur and I wanted to build something again from the ground up. I had an eye out for potential acquisitions and decided to go for it.” K Partners went on to participate in private equity and VC-backed investments spanning the media sector, publishing, telecoms, leisure and hospitality. Its interests included education publisher CJ Fallon and broadcaster Wilton Radio, now trading as iRadio and recently acquired by Bauer Media. The Netflix of payments Lennon’s vision for CleverCards is to see the venture become the “Netflix of payments”. “Our focus isn’t streaming obviously but I see our market opportunity in the same way,” he says.  “It’s pretty clear to me that everything is moving to the mobile phone and our focus is the configurability of payments. The market is wide open. There’s a big blue ocean of potential there and nobody else is doing it.” That said, he is under no illusion that crossing this “big blue ocean” will be plain sailing all the way. “It can be tough going in any early-stage business when you are trying to spot a gap in the market, launch a new product or service to fill that gap, and keep driving it through in the face of the forces that might be going against you,” he says. “There are challenges every day in business. People talk about an early-stage business being a rollercoaster and that is so true because it implies ups and downs,” he says.  “What people don’t realise is that there can be an up and a down in just one day. I don’t mean a small move in either direction. I mean really big ups and really big downs. You just have to deal with it and move on. You have to be resilient.” Interview by Elaine O’Regan

Despite housing and health and climate crises, our experience living and working in Ireland has never been so good, writes Cormac Lucey Come election time, the positions political parties advocate for can generally be classified into either continuity or change.  With a general election looming in the Republic no later than March 2025, the battlelines are already emerging. The parties of the outgoing Government will campaign for continuity. The parties of the opposition will seek change.  Ironically, despite the Government’s many policy failures (housing, health, etc.), it has a strong story to tell.  If a person were to choose when they would live in Ireland over the last thousand years, the rational choice would be today.  Life expectancy Take the very simplest index of national well-being. The average life expectancy in 1950 in the Republic of Ireland was 60. Today, it is just under 83 years old. This staggering progress reflects healthier lifestyles, better diets, safer workplaces and improved healthcare.  Income Income levels today are far ahead of those our parents and grandparents could aspire to. Last year, Ireland’s modified gross national income (the measure of national income designed to exclude globalisation effects) was €273.1 billion. This equates to income per head of €54,600.  The key to this is productivity growth. If productivity output per person grows at a rate of two percent per annum – the general experience over the 20th century – people should be 7.2 times as well off after a century.  If annual productivity growth is just one percent – roughly what we’ve experienced since the millennium – people will be just 2.7 times as well off after a hundred years. It is the slowdown in underlying productivity growth which is the most serious economic issue facing the global economy today. Employment We must also consider the range and depth of job opportunities available today. When I graduated from university in 1981, many of my classmates had to emigrate as the economic conditions were so poor in Ireland. Today, Ireland has record low unemployment. Young people travel the world for fun and to expand their horizons rather than out of financial necessity.  Ireland’s successful policy of attracting foreign direct investment to these shores means that people can work for the world’s largest and most financially successful companies without leaving the country.  Climate Young people may argue that, by presiding over damaging climate change, older generations have eaten the seed corn they will need.  A 2021 global survey led by the University of Bath in the UK illustrated the depth of anxiety many young people feel about climate change. Close to 60 percent of the young people approached said they felt very worried or extremely worried. Three-quarters said they thought the future was frightening. Fifty-six percent said they believe humanity is doomed. These widely held viewpoints illustrate the degree of public hysteria surrounding the debate over climate change.  Bjorn Lomborg (The Copenhagen Consensus Center, Copenhagen Business School and the Hoover Institution, Stanford University) recently made the point in Science Direct that scenarios set out under the UN Climate Panel (IPCC) show human welfare “will likely increase to 450 percent of today’s welfare over the 21st century. Climate damages will reduce this welfare increase to 434 percent”.  Lomborg expects that, in the context of general human progress, climate change will represent a speed bump rather than the end of the road.  To quote the former British Prime Minister Harold Macmillan, we’ve “never had it so good”.  Cormac Lucey is an economic commentator and lecturer at Chartered Accountants Ireland *Disclaimer: The views expressed in this column published in the October/November issue of Accountancy Ireland are the author’s own. The views of contributors to Accountancy Ireland may differ from official Institute policies and do not reflect the views of Chartered Accountants Ireland, its Council, its committees, or the editor.

Ronan McGovern, FCA, barrister and Stanford Scholar, talks about his experience living with ADHD and why more support is needed for neurodiversity at work  He is a Chartered Accountant, barrister and strategy manager with one of Ireland’s biggest banks but, for Ronan McGovern, the title he is most proud of is Stanford University Scholar. It was while studying for his MBA at the prestigious US university in 1996 that McGovern was first diagnosed with attention deficit hyperactivity disorder (ADHD). And it was through his continued work with Stanford that McGovern would go on to discover what he calls his “life purpose”. “In 2019, I was invited to work for six months on the Stanford Neurodiversity Project at Stanford Medical School, and it changed my life,” he explains.  “I discovered my unique offering to the world – what I was put on this earth to do; to be a neurodiversity champion and innovator.” His path to learning he had ADHD and discovering the world of neurodiversity was a long one, however. McGovern was already well into his thirties by the time he received his diagnosis. Although, these days, he views ADHD as the fuel powering “all the amazing things I have done in my life”, his experience growing up with the condition was not always positive. “I have been given these amazing gifts – academic excellence, creativity, ideas, energy, productivity – I stand out and I am authentically myself. I think differently but thinking differently wasn’t a good thing in the Ireland I grew up in,” he says. “In Irish society in the sixties and seventies, there was a very homogenous culture. Being different generally meant you were punished.” Early years McGovern grew up in the west Dublin suburb of Palmerstown and started primary school in 1965.  “It was long before there was any recognition of neurodiversity and I have to say I learned very little because my mind was always wandering,” he says. “Everybody’s mind wanders, but for an ADHD person, the inattention and mind-wandering are pronounced. The teachers had no idea I wasn’t learning anything. I just basically sat in class not telling them.” By the time he was ready to progress to secondary school in 1975, corporal punishment was still very much part of “the school culture” in Ireland, McGovern says.  “Some teachers saw me as what, in those days, they might have called a ‘a bold boy’, disrupting the class and with no apparent interest in learning,” he reflects. “During my time at secondary school, I would say corporal punishment was used on me maybe four or five times more often than my peers. “There was also shaming of different descriptions – I remember being put outside the door of the classroom as punishment – but that kind of treatment wasn’t exclusive to my secondary school at that time.” Despite this, McGovern’s academic performance remained strong throughout his school years with his exam results “ranging from average to top of the class”. “I believed in myself,” he says now. “Sometimes I was made to feel ‘less than’; I was shamed and ridiculed for being honest and straightforward, but throughout it all, I always believed in myself.” Path to diagnosis After leaving school, McGovern went on to train with a small accountancy practice and joined PricewaterhouseCoopers’ Dublin office in the early eighties. “In 1993, I was accepted into the MBA programme at Stanford Business School. The tuition at that time was about €30,000 per quarter so I decided to apply for a transfer to PwC New York for the sole reason of earning the money I would need to join the Stanford programme,” he says.  McGovern began his MBA studies in 1995 and was about eight months in when he was approached one day by one of his classmates.  “She said to me, ‘Ronan, I want to ask you a question. Have you ever heard of ADHD?’ I said no. She explained the condition and said that she had been watching me in class and believed I may have it,” he explains. “She was a doctor, and she knew a lot about autism and ADHD. She gave me a reference to the Stanford Medical Centre and told me they would point me in the direction of an educational psychologist who could assess me.”  Following a 10-hour assessment by an educational psychologist in Palo Alto, McGovern received a 15-page report.  “It told me that I had what was called Combined ADHD; a combination of hyperactivity and inattention. That was in early June 1996,” he says. “At the time, I felt a bit of sadness over the fact that I had not been diagnosed earlier, but I also felt a bit of relief and then excitement. My final observation was: Let me see what I can do in the future now that I have this diagnosis.” In the years since, McGovern has come to view his ADHD as “a gift”. “I bring creativity and ideas to the table,” he says, “an understanding of how everything is connected, be it biology, business or machine learning. That has really stood to me in my life and work.” Stanford Neurodiversity Project McGovern took a six-month career sabbatical in 2019 and returned to California to take part in the Stanford Medical School Neurodiversity Project. Led by Dr Lawrence Fung, the aims of the Stanford Neurodiversity Project include maximising the potential of neurodiversity and establishing a culture that treasures the strengths of neurodiverse individuals.  It defines neurodiversity as “a concept that regards individuals with differences in brain function and behavioural traits as part of normal variation in the human population” and says, “the movement of neurodiversity is about uncovering the strengths of neurodiverse individuals and utilising their talents to increase the innovation and productivity of society as a whole”. Following his six-month stint on the neurodiversity project, McGovern took part in Stanford Rebuild Innovation Sprint, launched in 2020 to help develop solutions for the challenges and opportunities society would face in the wake of the COVID-19 pandemic. “Stanford invited alums and others to initiate an entrepreneurial project aimed at rebuilding society,” he explains. “Professors gave their time to assist volunteers and I volunteered to do something on neurodiversity in business and formed a core team with Susan O’Malley, an Irish Stanford business school alum, and Tiffany Jameson, a neurodiversity consultant.  The group recruited 50 other volunteers and, “over three months in the summer of 2020, we all co-authored our Stanford Rebuild Report,” McGovern says. “When our Rebuild project drew to a close that August, we formed NDGiFTS to prevent this work coming to an end.” NDGiFTS stands for Neurodiversity Giving Individuals Full Team Success and is, McGovern explains, a movement dedicated to building a “global community whose aim is to increase the inclusion and celebration of neurodiversity at work”.  To this end, NDGiFTS has produced a 78-page report, available at ndgiftsmovement.com, with input from 70 contributors and insights from 300 stakeholders worldwide. NDGiFTS’ mission “The mission of the NDGiFTS movement is to prove that neurodiverse individuals are worth investment from organisations who stand to reap the reward of innovation,” McGovern says. “Our core belief is that the neurodivergent individual, when appropriately supported and embraced, brings cultural and economic advantages to the workplace, including creativity, innovation and entrepreneurial energy.”  According to McGovern, as many as 20 percent of people worldwide have neurodivergent conditions ranging from ADHD and autism spectrum disorder to dyslexia, dyscalculia and dysgraphia. “Even now, all these years since my diagnosis, the sad truth is that society has not yet built the structures to support and service people who are neurodiverse,” he says. “This applies as much to the business environment, apart from a very small minority of companies, Goldman Sachs being a particular exception to the rule.” In 2019, the US banking giant launched the Goldman Sachs Neurodiversity Hiring Initiative, an eight-week paid internship for people who identify as neurodiverse. “It went on to hire more than 50 neurodivergent people over three years. Every one of the participants in that internship programme was made a permanent employee,” McGovern says. As it stands, however, Goldman Sachs remains the outlier with few organisations having made the same strides in neurodiversity inclusivity. McGovern is, meanwhile, once again partnering with Stanford University to publish a book in 2024 that will detail his experiences growing up and living with ADHD. “My own experience of work was that my experience at school carried through to my professional life. When I was challenged to progress in a certain role, I found the perception was that I didn’t fit the mould of my other colleagues,” he says. “My message now is that we need to focus on the intentional recruitment of the neurodiverse talent base, similar to the Goldman Sachs model. “I would like employers to look at my personal journey and start thinking seriously about neurodiversity and the potential of people like me.  “My story is not unique, but I think I can help to open a serious conversation about neurodiversity in Ireland and around the world. We should not have a society where people spend all their time swimming against the tide.” Written by Elaine O’Regan

Accountants will be the profession best placed to bring the necessary rigour to the analysis and governance of critical data in the age of AI, writes Sharon Cotter Canadian philosopher Marshall McLuhan has suggested: “We become what we behold. We shape our tools, and thereafter our tools shape us”. This is important to remember today, when the spotlight is on the potential consequences, intended and unintended, of the artificial intelligence (AI) tools being shaped by humans. The rise of AI AI encompasses a vast range of computer science research. Since the 1950s, scientists have pursued the goal of building machines capable of completing tasks that normally require intelligent human behaviour.  Machine learning (ML), a subset of AI, enables machines to extract knowledge from data and to learn from it autonomously.  In the past decade, the exponential increase in the volume of data generated, captured, stored and available for analysis, coupled with advances in computing power, have created the impetus and means to rapidly advance ML, which in turn has facilitated the development of narrow AI applications.  In essence, narrow AI applications are computer programs, or algorithms, specifically trained, using very large datasets, to carry out one task, or a limited number of tasks. Best suited to tasks that do not require complex thought, narrow AI algorithms can often accomplish such tasks better and more swiftly than humans.  Most of the AI capability we use today is narrow AI – from Alexa and Siri, which carry out human voice commands, to ChatGPT and Bard, which generate output based on conversational text prompts, and Dall-E2, which generates visual images based on text prompts, to name but a few.  In the field of accounting, we can utilise coding languages and software tools such as Python, ‘R’ and Alteryx to generate predictive forecasts and models.  We often use these tools without realising that we are using elements of narrow AI. For example, these programming languages and software tools embed many of the statistical algorithms that allow us to easily carry out linear regression analysis, a common method of predicting future outcomes based on past data. Adapting to broaden our role The word ‘computer’ was first coined by the English poet Richard Brathwaite in 1613 to describe a person who carried out calculations or computations. For the next 350 years or so, most humans who needed to perform calculations used mental arithmetic, an abacus or slide rules until the widespread availability of electronic handheld calculators in the 1970s. As accountants, we have seamlessly adapted to the tools available to us – whether these are an abacus, double-analysis paper, a totting machine, or computer software tools like Excel and Alteryx.   The use of these tools, and the time saved by their use, have allowed us to broaden our role from recording, summarising and presenting the underlying economic transactions to providing a much wider range of useful information to decision-makers both within, and outside, organisations.  This is reflected in commentary from the professional accountancy bodies emphasising the importance of good organisational decision-making and suggesting that the core purpose of our profession should be to facilitate better decisions and identify the business problems that better decisions will resolve. Asking the right questions In 1968, Pablo Picasso is reputed to have said: “Computers are useless. They can only give you answers”. While the remark may have been dismissive of the then cumbersome mainframe computer, it does encapsulate the notion that the real skill lies in figuring out the right question to ask, as this requires both judgement and creativity.  Useful, timely and relevant information for decision-making can only be produced if the right question is asked of the right data at the right time. On the face of it, this seems simple and straightforward, but in practice it is often much more difficult to achieve.  Deciding what question to ask requires knowledge of the business context, and an understanding of the issue being addressed as well as an ability to clearly articulate the issue. Critical thinking is key to identifying what answers are needed to identify the range of solutions for the issue at hand. Deciding what data is appropriate to use in the analysis requires an understanding of what data is available, where it is stored, how it is stored, what each data element selected represents, how compatible it is with other data, and how current that data is. It also requires knowledge of the limitations posed by using particular sets of data. Being able to generate the answer to the right question using the right data is only relevant if it can be produced at the point at which this information is needed. Sometimes, not all the data needed to answer the question is readily available, or available in the required format. Data from several sources may need to be combined and, where data is incomplete, judgement will be needed on the assumptions necessary to generate a relevant and timely set of data. Accountants are well-positioned The skills, experience and mindsets we develop as part of our professional training positions accountants well to provide the best possible decision-enabling information to decision-makers.  Scepticism is a key tenet of our profession. We look to spot anomalies in data and information, and to question the information by asking “does it make sense?” We are trained to be methodical, thorough and to look beyond the obvious. Training and experience enable us to develop our professional judgement, which we apply when determining what is relevant, appropriate and faithfully represents the underlying economic transactions.  We are adaptable and flexible in the tools we use, and aware of the need to stay up to date with the law and regulation applying to the storage and use of data. In short, we are valued problem-solvers and critical thinkers. Accountants’ ‘jurisdiction’ In his book The System of Professions: An Essay on the Division of Expert Labor, Andrew Abbott uses the term ‘jurisdiction’ to represent the link between a profession and its work.  Jurisdiction is an important concept, as the acknowledged owner of a task is likely to be able to shape the characteristics of that task. In the context of accountants’ work, the term ‘jurisdiction’ means the extent to which organisations, and society, accept that due to their professional expertise, only specific roles and responsibilities should be carried out by accountants.  Within organisations, accountants’ jurisdiction is not static. The roles and responsibilities that fall within their remit can, and do, change.  The jurisdiction of accountants can be encroached upon. Others within the organisation may also have expertise allowing them to claim work once exclusively identified with accountants. Challenges to jurisdiction The emergence of new roles, such as data or information specialists, who collect, clean and analyse data, has meant that complex analysis of financial information can now be done by non-accountants.  Some organisations have explored ways in which operational managers and decision-makers can be given direct access to financial systems.  Known as ‘self-service’ menus, such direct access to information allows decision-makers to drill down into the detail of transactions – for example, to identify the underlying causes of deviations from budget, all without the need to consult with their colleagues in the finance department.  If an organisation transfers responsibility for data analysis and decision support to data specialists and/or decision-makers, then the jurisdiction of the accountant may be narrowed or reduced. Opportunities for role expansion Equally, however, accountants’ roles and responsibilities can be increased, resulting in their jurisdiction being broadened or expanded.  The expansion of an accountant’s role requirements can either result from increased job tasks and responsibilities, or from changes in the tools and technologies available to carry out these tasks and responsibilities.  Recent research and professional body commentary has, for example, explored the extent to which management accountants have embraced changes in their role or taken on wider responsibilities, such as business partnering.  Multiple elements such as role identity, the ability to embrace change in a positive way and developing strong communication skills, to name but a few, all contribute to the successful adoption of additional responsibility. Futureproofing with digital fluency The rapid and on-going development, enhancement and availability of software tools that can be used to capture, store, identify, slice and dice data, and present information in visual graphics, are forcing accounting professionals to consider the level of IT competency required to operate efficiently and effectively in today’s digital world.   Professional accountancy bodies emphasise the importance of digital skills in futureproofing the accountant’s role while many of the larger multinational companies espouse the need for finance staff to have good digital fluency. Challenges and opportunities Both encroachments and expansions to the jurisdiction of accountants bring their own set of challenges and opportunities.  Maintaining, and expanding, accountants’ jurisdiction over the integrity of data, and the provision of information for decision-making, should be a key part of the profession’s strategy in the digital age.  I believe that the ‘governance’ of data, rather than the use of specific AI tools, should be the focus of the accountancy profession when formulating strategies for its future direction. In addition to enhancing our digital skills, we need to consider strategies such as adapting and changing the role of the chief financial officer to include overall direct responsibility for data analytics.  The governance, management and analysis of data should be as important as traditional responsibilities in finance.  Governance of data requires rigour and objectivity to ensure that its integrity is preserved. We should noticeably stake our claim as the profession best placed to bring that rigour and objectivity to the governance and analysis of data used for decision-making.  Failure to consider such strategies may mean we increase the risk that encroachments rather than expansions to our role – our jurisdiction – will become a reality. We should strive to ensure that our future role is shaped by us rather than by these new digital tools and techniques. Sharon Cotter, FCA, lectures in accounting and finance at the University of Galway

The Financial Reporting Council (FRC) have released FRED 84 in recent days which proposes some amendments to FRS 102, and specifically disclosures relating to supplier finance arrangements. The changes are based on similar amendments made to IAS 7 Statement of Cash Flows and introduce new disclosure requirements in respect of supplier finance arrangements. These amendments are intended to improve the information available to users where an entity who prepares a cash flow statement enters into a supplier finance arrangement. It is proposed that the amendments will be effective for periods beginning on or after 1 January 2025, with early adoption permitted. As many entities are either small, a qualifying entity claiming exemption from preparing a cashflow statement or do not have any supplier finance arrangements, these changes are expected to impact only a small number of companies. Supplier finance arrangements are characterised by one or more finance providers offering to pay amounts an entity owes its suppliers and the entity agreeing to pay according to the terms and conditions of the arrangements at the same date as, or a date later than, suppliers are paid. These arrangements provide the entity with extended payment terms, or the entity’s suppliers with early payment terms, compared to the related invoice payment due date. Supplier finance arrangements are often referred to as supply chain finance, payables finance or reverse factoring arrangements. Arrangements that are solely credit enhancements for the entity (eg financial guarantee contracts) or instruments used to settle directly with a supplier the amounts owed (eg credit cards) are not supplier finance arrangements. The FRED 84 consultation remains open for comment until 31 December 2023.

The Institute is currently considering amendments to the Audit Regulations UK.  The proposed amendments would align the Audit Regulations UK more closely with the Institute’s Audit Regulations, Ireland.    The key changes proposed can be summarised as follows: A new requirement for audit-registered sole practices (both individual sole practitioners and single-director corporate practices) to put in place alternate arrangements which would take effect in the event of the death or incapacity of the sole practitioner. Additional material to clarify the obligations of audit firms and responsible individuals (RIs) in relation to continuing professional development requirements (CPD). The ability for the Quality Assurance Committee to impose regulatory penalties on RIs. It is anticipated that the revised Audit Regulations UK would become effective from 1 January 2024 (pending necessary approvals) with a proposed transition period of six months thereafter for compliance with the requirement for audit-registered sole practices (to put in place alternate arrangements). The Audit Regulations UK set out the Institute’s rules for the authorisation and supervision of statutory audit firms and RIs in the UK.  The Audit Regulations UK are issued jointly by Chartered Accountants Ireland (the Institute), the Institute of Chartered Accountants in England and Wales (ICAEW) and the Institute of Chartered Accountants of Scotland (ICAS).  A public consultation is ongoing in relation to the draft revised Audit Regulations UK.  The details of this consultation and the draft revised Audit Regulations UK are available to read here.   Audit firms and RIs registered for audit in the UK by Chartered Accountants Ireland and who wish to provide comments in relation to the draft revised Audit Regulations UK can email those comments to professionalstandards@charteredaccountants.ie

Your Individual Annual Return 2023 is now available for completion online.  Please ensure it is submitted by 31 October 2023. Click here for your Individual Annual Return. Please note, timely completion will ensure that all members in practice are invoiced correctly for 2024 Regulatory Fees.

Minister Dara Calleary, TD has signed the Companies Act 2014 (Section 682) Regulations 2023. The Regulations, which came into effect on 1 October 2023, prescribe a revised Report for use by liquidators when making reports to the Corporate Enforcement Authority under section 682 of the Companies Act 2014. The revised section 682 report should be used for all submissions made from 1 October 2023. The Rules of the Superior Courts (Order 74) 2023 also commenced on 1st October 2023. There are two new questions included: - Question 22 requires the liquidator to confirm whether the directors have demonstrated that they have had regard to the interests of their employees in accordance with the requirements of section 224 of the Companies Act 2014. - Question 32 requires additional information where liquidators are asked to indicate whether they have advised directors, in respect of whom relief is not sought, of the grounds upon which an application to have them restricted will be brought.

The FRC have issued a project update relating to the ongoing periodic review of FRS 102 and FRS 105. In its update, the FRC noted that they received 54 response letters to FRED 82 and they are now preparing final amendments for issue which will take into account the responses received. Earlier this year, the Institute’s Financial Reporting Technical Committee issued a response to FRED 82. The FRC have indicated that they expect to issue the final amendments to FRS 102 and FRS 105 in the first half of 2024, with an expected effective date of periods commencing on or after 1 January 2026 for the changes. This is 1 year later than the date proposed in FRED 82. The FRC are working on amendments to the standards and provided updates on the revenue recognition and lease accounting sections which respondents provided feedback on during the consultation process. They will continue to work towards a “five-step model” for all FRS 102 and 105 preparers, while seeking simplifications to ensure proportionality for micro-entities. In addition to this, they have indicated that they will consider how to ensure that the “on-balance sheet” model of lease accounting under FRS 102 will be proportionate and understandable for FRS 102 preparers of all sizes.

The Institute has responded to the International Accounting Standards Board’s (IASB) request for information relating to IFRS 9 Financial Instruments impairment requirements. The IASB’s request for information begins the post-implementation review of IFRS 9’s impairment requirements and this allows the IASB to assess whether the effects of applying the new requirements on users of financial statements, preparers, auditors and regulators are those the IASB  intended when it developed the requirements. IFRS 9 has been effective for annual periods beginning on or after 1 January 2018. Some of the key points made by the Financial Reporting Technical Committee on behalf of the Institute include; Broadly speaking, the impairment model in IFRS 9 is working as intended and produces relevant and reliable information. There are some areas where users of the standard would benefit from additional guidance and educational material (for example- the definition of credit losses, calculation of expected credit losses on inter-group loans which are repayable on demand and interaction of impairment with other IFRS standards). There is a high cost of applying the impairment requirements to intercompany loans, often with limited benefit due to investors often placing greater reliance on the consolidated financial statements. The simplified approach for trade receivables, contract assets and lease receivables is working well in practice and is widely used. A recommendation that the IASB provide guidance regarding minimum disclosure requirements in IFRS 7 to achieve greater consistency in the information provided. The increasing prevalence of questions arising in relation to ESG risk when applying impairment requirements and the need for more guidance and educational material.

Last week we notified readers that the Institute is meeting with HMRC tomorrow to discuss the 31 October 2023 deadline for using the VAT margin scheme for second hand vehicles purchased from Great Britain and moved to Northern Ireland before 1 May 2023. Sales of such vehicles after the end of the VAT margin scheme on 31 October 2023 will mean that VAT must be charged on the full selling price. These vehicles do not qualify for the VAT related payment scheme which commenced on 1 May 2023. Today is the deadline for providing us with supporting evidence that many of these vehicles are currently unsold and are expected to remain unsold on 31 October 2023. A reminder of the evidence that HMRC is seeking is set out below.  HMRC has requested details or estimates in respect of the following:- The numbers of second-hand vehicles dealers in Northern Ireland had in stock on 1 May 2023 that were sourced from Great Britain;  How many of these remain unsold at present, and their estimated value;  How many are likely to be unsold on 31 October 2023, and their estimated value; and  If there is any category of vehicle that may be particularly affected by having a cut-off date of 31 October 2023 after which the margin scheme could no longer be used.  We recognise that many dealers may not be able to provide all of the detail requested in such a short period of time, especially the category of vehicle, but any information or evidence to support the difficulties being experienced in selling these vehicles would be appreciated.  The meeting will also be an opportunity to discuss the new second-hand motor vehicle VAT related payment scheme. Feedback on the end of the VAT margin scheme and the new VAT related payment scheme should be emailed to the Institute by the end of today Monday 2 October 2023. 

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. We also update you on recent developments in relation to the Windsor Framework and the latest Trader Support Service (“TSS”) bulletin is also available. Last week it was  announced that the TSS is being extended one further year to 31 December 2024. The Institute has been lobbying for a further extension to the TSS and welcomes this decision but will be considering what permanent supports are needed in this area in future.  Update on the Windsor Framework  Last week HMRC published further details on the Windsor Framework as some significant elements of it began to take effect from the end of September.   From 30 September 2023, the new UK Internal Market Scheme expanded the range of businesses able to benefit from the new arrangements provided to protect internal UK movements, including the removal of EU tariffs. In tandem, the new sanitary and phytosanitary “green lane” arrangements took effect, including the new Retail Movement Scheme for agrifood retail products, new rules to allow plants to move into Northern Ireland and new arrangements to enable seed potatoes to move once again from Great Britain to Northern Ireland. As these changes bed down in the coming weeks and months, contact us to share your feedback and any problem areas which arise.  Miscellaneous updated guidance etc.   The following updated guidance, and publications relevant to EU exit are available:-  Customs declaration completion requirements for goods subject to sanitary and phytosanitary checks under the Northern Ireland Protocol;  Draft Decision No 1/2023 of the Specialised Committee on Participation in Union Programmes under the Trade and Cooperation Agreement adopting Protocols I and II and amending Annex 47 to the Trade and Cooperation Agreement;  Third Trade Specialised Committee on Customs Cooperation and Rules of Origin Agenda;  Using the Trader Dress Rehearsal service;  List of customs training providers;  Making an import supplementary declaration;  Making a simplified frontier declaration;  Making a full import declaration;  Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service;  Receive goods into and remove goods from an excise warehouse (Excise Notice 197); and  Paying additional excise duty for goods moving to Northern Ireland.   

The OECD has released the latest outcomes on the implementation of Country-by-Country reporting (CbCR). CbCR is the reporting mechanism which gives effect to BEPS Action 13 and requires tax administrations to collect and share detailed information on large multi-national enterprises operating in their jurisdiction. The OECD has reported that implementation of CbCR in countries has largely been consistent with the Action 13 minimum standard.

The Carbon Border Adjustment Mechanism (CBAM) has entered its transitional phase. CBAM is Europe’s landmark tool to combat carbon leakage. It equalizes the price of carbon between domestic products and imports ensuring Europe’s climate policies are not undermined by less rigorous green standards in third countries. In last Friday’s Sustainability Bulletin, the Institute’s Sustainability Officer, Susan Rossney, included an update on the measure.

In its response to the consultation “Taxation of Employee Ownership Trusts and Employee Benefit Trusts”, the Institute’s Northern Ireland Tax Committee has recommended that the UK Government undertake a full review of UK employment taxes policy, which should be targeted at assessing how this could be harnessed and reformed to ultimately incentivise employment and reduce the current labour and skills shortages in the UK.  The Committee’s submission also includes a number of recommendations which seek to reduce the cost of employment in certain areas and also recommends that an enhanced form of tax relief for training employees in key skills areas, in the form of a super deduction, should be introduced. Read the Committee’s full recommendations on page 7 of the submission.

Last week we told you about changes which HMRC is making to the waiting times on the Agent Dedicated Line (“ADL”) which take effect from today, Monday 2 October 2023. The Institute wants to hear from agents calling the ADL in the next few weeks as we continue to discuss this change, and its impact, with HMRC. Broadly, the changes will mean longer waiting times with certain types of PAYE calls being rerouted to other helplines. HMRC has since shared some further information and messaging on the changes, which we have outlined below. HMRC’s Representative Body Steering Group forum, at which these changes are being discussed with us and the other Professional Bodies, has passed all feedback received to the various HMRC operational teams implementing them. For example, at present there remains a lack of clarity around the types of PAYE queries which will be diverted to other helplines. We expect to hear more on this aspect in the coming weeks.   It is also unclear how much longer an agent may expect to wait. HMRC has advised us that it will be closely monitoring the revised service and will provide further clarification which will be included in October’s Agent Update publication.  Further discussions will also be held with the Professional Bodies hence why we urge you to get in touch and share your experiences and feedback on the impact of these changes as they bed down. 

This week we bring you HM Treasury’s response to the Institute’s letter on changes to the geographical scope of agricultural property relief and the latest report from the Administrative Burdens Advisory Board (“ABAB”) has been published. At a recent meeting HMRC advised that although the marriage allowance online form is not currently mandatory, using the form may mean that claims are processed quicker. HMRC has also issued another reminder email on the recent alcohol duty changes which took effect from 1 August 2023 and a detailed update has been published on the actions identified at the February 2023 HMRC Stakeholder Conference. And finally, the latest news and information bulletin from HMRC is available.  HM Treasury responds to letter on changes to the geographical scope of agricultural property relief  At end of August, the Institute’s Northern Ireland Tax Committee wrote to the Financial Secretary to the Treasury to express its concerns in respect of the proposal to restrict the geographical scope of agricultural property relief (“APR”) and woodlands relief (“WR”)  from April 2024. HM Treasury has now responded to that letter which you can read on our website.   The Institute recently submitted evidence to the House of Lords Finance Bill Sub-Committee  inquiry into Finance Bill 2023-24 and once again raised its concerns in relation to the APR and WR draft legislation, in addition to the proposal to merge the UK’s R&D tax relief schemes from April 2024. Members will be able to read this submission when the Committee confirms it has accepted the submission as evidence.  Latest report of the Administrative Burdens Advisory Board (“ABAB”)  The Tell ABAB Survey report was recently published and details responses to April’s ‘Tell ABAB Survey’, which this year had a record 7,500 responses. In previous years, responses have averaged around 3,000. Of the responses, 86.9 percent came from businesses and 12.7 percent from tax agents. This represents a significant shift from 2022 when 67.8 percent of responses were from businesses and 32.2 percent from agents.  Board members come from a range of businesses and professions, with their goal being to make “a noticeable difference for small business by supporting HMRC in:-  helping to reduce administrative burdens; and  ensuring that the tax system is easier, quicker, and simpler.”  The key findings from the survey reveal that burdens on business remain a significant concern and they continue to increase year on year. Off-payroll working rules, Making Tax Digital and changes in importing and exporting procedures have contributed to increasing burdens during the survey period. Additionally, businesses state that they have not witnessed benefits of digitalisation yet.  The shift to nomadic working poses challenges. According to the survey, 59.5 percent of those who worked from home or had employees working from home or as nomadic workers, were familiar with HMRC’s working from home guidance. Whilst this percentage might look relatively high, these workers now form a significant part of the workforce, with over 63 percent of respondents stating that they were working from home or as nomadic workers.  There is definite evidence from the survey that guidance to business is improving. Many respondents rated the ease of understanding written correspondence and the information on YouTube videos highly. Whilst there are still problematic HMRC forms, the numbers here are relatively low and although there are remaining frustrations with GOV.UK, these are also relatively low.  Another important message is that respondents continue to express a strong desire to speak to a human advisor. Satisfaction levels on response times for telephone calls remains low, with respondents being dissatisfied with this service for that reason. 

Thursday 5 October 2023 is the deadline to notify HMRC of a new source of income or gain for 2022/23.  Those required to register for self-assessment are:- Anyone who is self-employed or a sole trader which commenced in 2022/23; Anyone not self-employed but who had a new source of income or a gain in 2022/23; or  Anyone who became a partner in a partnership, or a new partnership commenced in business in 2022/23.   Failure to register by the deadline can result in HMRC charging a failure to notify penalty.