Accountants Trust Account Audit ACT: Reliable & Affordable
Reliable, Affordable, and Expert Trust Account Audits for ACT Accountants – Ensuring Compliance with Trusted Professionals.
If your accounting practice in the Australian Capital Territory holds or receives money on behalf of clients, you have a legal and professional obligation to have that arrangement audited every year. This applies whether you operate a formal trust account, accept advance payments, or hold signatory authority on a client’s bank account.
The governing standard is APES 310 Client Monies, issued by the Accounting Professional and Ethical Standards Board (APESB). It is not the same legislation that applies to real estate agents. Many ACT accounting practices come to us after working with auditors who conflated the two, and the errors that result can trigger a modified report and professional body review.
At Number Solutions Tax & Accounting, we conduct APES 310 compliance audits for accounting firms across the ACT and greater Canberra region. Our team understands what the standard requires, what your professional body expects, and how to complete the engagement accurately within your applicable deadline.
What is APES 310, and why does it govern ACT Accountants with Client Monies
APES 310 Client Monies is a mandatory professional standard issued by the APESB. It came into effect in December 2010 and was most recently revised in October 2024, with the updated version applying to engagements commencing on or after 1 April 2025.
The standard applies to all members in public practice in Australia who deal with client monies. This means any member of CPA Australia, Chartered Accountants Australia and New Zealand (CA ANZ), or the Institute of Public Accountants (IPA) who holds a current Public Practising Certificate and meets one of the following conditions:
- Operates a trust account to receive client funds such as tax refunds
- Accepts advance payments or deposits from clients before services are provided
- Has been given authority to transact on a client’s bank account, including via accounting software
- Has staff members who can authorise transactions on behalf of a client
If any of those situations describe your ACT practice, APES 310 a
What APES 310 Actually Requires Your Practice to Do
Beyond the annual audit, APES 310 sets out ongoing obligations that every covered accounting practice must meet throughout the year:
- Keep all client monies completely separate from your firm’s own funds at all times
- Reconcile trust account balances at least every 25 business days
- Correct any discrepancy or error found during reconciliation within 5 business days
- Issue year-end statements to clients within 30 business days of your applicable year-end date
- Appoint a qualified, independent auditor and notify your professional body of that appointment
- Ensure your annual compliance audit is completed within 3 months of your applicable year-end
These obligations run continuously, not just at audit time. Practices that only focus on compliance in the weeks before the audit are the ones most likely to receive a modified report.
How the Year-End Date Works for ACT Accountants
This is where many practices get confused. Your applicable year-end date under APES 310 is not automatically 30 June.
When Your Trust Account Was Opened | Applicable Year-End Date | Audit Due |
Before 1 July 2011 | 31 March each year | 30 June |
After 1 July 2011 | 12 months from the month-end following account opening | 3 months after that date |
Once your year-end date is set, it cannot be changed without approval from your professional body. If you are unsure of your year-end date, contact CPA Australia, CA ANZ, or IPA directly before booking your audit.
Not sure if your ACT accounting practice meets APES 310 Client Monies requirements?
Our experts review your records and ensure your client money arrangements stay fully compliant before your annual deadline.
We help ACT accounting practices stay compliant and audit-ready with an affordable, independent APES 310 compliance audit.
- Dedicated client monies audit for ACT accounting firms
- Fast and straightforward
- Clear, practical fixes explained simply
Who Can Legally Audit an Accountant's Trust Account in the ACT
Under APES 310, the auditor of your client’s monies must be another member in public practice holding a current practising certificate from one of the three recognised professional bodies: CPA Australia, CA ANZ, or IPA.
You do not need a Registered Company Auditor for an APES 310 engagement. However, you absolutely cannot use:
- Anyone within your own firm, including partners or employees
- A person who has been employed by or associated with your practice in a way that compromises their independence
- Someone who is themselves a client of your firm
- Any person who does not hold a current practising certificate from a recognised body
Why Independence Is Non-Negotiable
APES 310 requires auditors to comply with the independence requirements set out in APES 110 Code of Ethics for Professional Accountants, specifically the sections covering conflicts of interest and custody of client assets.
The independence requirement exists because the audit is a compliance engagement. It is not a financial statement audit, but it still requires the auditor to reach an independent conclusion about whether your practice has met the requirements of the standard. An auditor with any financial, personal, or professional connection to your practice cannot objectively form that conclusion.
Engaging a non-independent auditor does not just weaken the audit. It invalidates the engagement entirely and leaves your practice in the same position as having no audit at all.
Modified Reports and Lodgement Obligations
An unmodified APES 310 audit report does not need to be submitted to your professional body, but it must be retained and made available if requested during a Best Practice Program review.
A modified report is different. If the auditor identifies material non-compliance with APES 310, they must forward the modified report to your professional body within 15 business days of completing the engagement. Your professional body may then initiate further review or disciplinary action depending on the nature of the findings.
Common reasons a modified report gets issued include:
- Reconciliation completed less frequently than every 25 business days
- Disbursements made without proper client authorisation
- Client monies commingled with business operating funds
- Year-end statements not issued to clients within the required timeframe
- Trust account funds used to offset bank charges or fees
The Difference Between a Reasonable Assurance Engagement and a Limited Assurance Engagement
APES 310 provides for two types of audit engagements depending on your specific circumstances. Understanding which one applies to your practice is important before you engage an auditor.
Reasonable Assurance Engagement
This is the standard audit engagement required when your practice operates a dedicated trust account. The auditor performs a higher level of testing and evidence gathering and provides a positive conclusion confirming that, in all material respects, your practice has complied with the requirements of APES 310.
This type of engagement is conducted in accordance with ASAE 3100 Compliance Engagements under the Australian Auditing and Assurance Standards.
Limited Assurance Engagement
This applies to a narrower set of circumstances. If your practice does not operate a trust account but holds co-signatory authority on a client’s bank account alongside the client, APES 310 permits a limited assurance engagement rather than a full reasonable assurance audit.
Under a limited assurance engagement:
- The auditor performs fewer procedures and gathers less evidence
- The conclusion is expressed in a negative form: the auditor states that nothing has come to their attention to suggest non-compliance
- The engagement is still conducted by a qualified, independent member in public practice
Feature | Reasonable Assurance | Limited Assurance |
Who it applies to | Practices with a trust account | Co-signatories on client bank accounts only |
Level of testing | Higher, more extensive procedures | Reduced, targeted procedures |
Conclusion format | Positive assurance statement | Negative assurance statement |
Standard applied | ASAE 3100 | ASAE 3100 (modified scope) |
Auditor requirement | Independent member in public practice | Independent member in public practice |
If you are unsure which engagement type applies to your ACT practice, Number Solutions will assess your client money arrangements during the initial consultation and confirm the correct engagement type before any work begins.
How Number Solutions Conducts APES 310 Trust Account Audits for ACT Practices
Our process is structured to minimise disruption to your practice while giving your professional body exactly what it needs to confirm compliance.
Step 1: Free Initial Consultation
We start by understanding your practice. We confirm your applicable year-end date, identify whether you need a reasonable or limited assurance engagement, and establish what records we will need to complete the audit efficiently.
Step 2: Document Collection
We provide a clear checklist of everything required. This typically includes:
- Trust account bank statements for the full audit period
- Reconciliation records showing each reconciliation and its date
- Client ledgers and transaction logs
- Records of all deposits, withdrawals, and disbursements
- Evidence of client authorisation for transactions
- Year-end statements issued to clients (or confirmation of issue dates)
- Any previous audit reports relevant to the current period
Step 3: Compliance Testing
Our team works through the APES 310 requirements systematically. We test the controls and procedures your practice has in place, verify transaction records against bank statements, confirm reconciliation frequency, and check that client notifications and statements were issued within the required timeframes.
We also review whether any bank fees or charges were correctly handled. Under APES 310, fees on trust accounts must be charged to your firm’s general account, not deducted from the trust account itself.
Step 4: Reporting
Once the testing is complete, we prepare the audit report in the required format. If the engagement produces an unmodified finding, we provide you with the report to retain for your records. If we identify any issues during testing, we discuss them with you before finalising the report so you understand exactly what the finding is and what corrective action is needed.
We do not issue a modified report without first walking you through the finding and confirming the facts are correct.
Book your free ACT accountants' trust account audit consultation today.
Call Number Solutions on 02 9174 5327 or complete the contact form to speak with our team. We work with public accounting practices across Canberra, the ACT region, and throughout Australia for remote APES 310 engagements.
Why ACT Accounting Firms Choose Number Solutions for Their Annual Client Monies Audit
The ACT accounting community is close-knit. Practices here need an auditor who knows APES 310 thoroughly, completes engagements on schedule, and communicates clearly when questions arise.
We Know APES 310 Specifically
Our team does not apply a generic trust account audit approach across different industries and standards. We understand that an accountants’ trust account audit under APES 310 is a compliance engagement, not a financial statement audit, and we conduct it accordingly.
This distinction matters. The procedures, the evidence standards, the reporting format, and the lodgement obligations are all different from what applies to real estate agents or solicitors. Using an auditor who blurs these lines creates compliance risk for your practice.
Fixed Fees with No Hidden Costs
Trust account audits under APES 310 are typically smaller engagements than statutory audits, and our pricing reflects that. We provide a fixed fee before we begin so your firm can budget accurately. There are no additional charges for follow-up questions during the year or for explaining findings in the debrief.
Importantly, APES 310 is clear that audit fees must not be paid from the trust account itself. The cost is a business expense to your firm, and we make sure our invoicing is structured accordingly.
Remote Audits Available Across the ACT
We work with ACT accounting practices remotely, which means you do not need to be based in Canberra CBD or arrange for us to attend your office. Document sharing is handled securely, and all communication takes place through clear, direct channels with no unnecessary delays.
Key reasons ACT practices work with us:
- Correct application of APES 310 rather than a real estate audit template
- Fixed pricing before we start, no scope creep
- Clear pre-audit checklist so you know exactly what to gather
- On-time completion within your three-month audit window
- Transparent reporting with findings explained clearly before the report is finalised
- Advisory support available between audit periods when compliance questions come up
FAQs
APES 310 requires an independent auditor because the engagement is a compliance assurance engagement. The auditor provides an objective opinion to your professional body that your practice has met the standard’s requirements. An internal reviewer, bookkeeper, or anyone closely associated with your firm cannot satisfy this requirement under APES 110. Using a non-independent auditor invalidates the engagement entirely.
Select a member in public practice from CPA Australia, CA ANZ, or IPA who holds a current practising certificate and is independent of your firm. Once they accept the appointment, notify your professional body. Both CA ANZ and CPA Australia require notification when an auditor is appointed or changed. If you switch auditors, both parties must advise the professional body of the reason, as this rule exists to prevent opinion shopping. Number Solutions handles the notification steps as part of the engagement setup.
Not every accountant. The requirement applies to members in public practice (CA ANZ, CPA Australia, or IPA members) who hold a current Public Practising Certificate and deal with client monies. This includes operating a trust account to receive tax refunds, accepting advance payments, or holding signatory authority on a client’s bank account. If your practice handles none of these activities, APES 310 does not apply to your trust account obligations.
Yes. APES 310 does not provide an exemption based on the frequency or volume of client money held. If you have a trust account or authority to transact on client funds at any point during the year, the annual compliance audit requirement applies regardless of how rarely you use it.
