Timings and deadlines
In response to the Coronavirus pandemic the Ministry for Housing, Communities and Local Government (MHCLG) issued new Statutory Instruments that affect the limited assurance regime process.
SI2020/392 and SI2020/808
Local authorities were granted permission to allow members, the public and press to attend meetings remotely from 4 April 2020 for all smaller authorities except parish meetings and from 1 August 2020 for parish meetings.
- The statutory deadline for publishing the approved Sections 1& 2 of 2019/20 AGAR and for authorities not claiming exemption, Section 3 (the external auditor’s certificate), was extended from 30 September 2020 to 30 November 2020.
- The requirement for all smaller authorities to include a common period for the exercise of public rights for the 2019/20 year was removed; this was previously the first 10 working days of July.
- The requirement for all smaller authorities to set a 30-day period for the exercise of public rights for 2019/20 starting on or before 1 September was introduced.
- As a result of the above the requirement for the 2019/20 AGAR to be approved on or before 31 August 2020 was introduced; this was previously 30 June 2020.
The AGAR forms were not updated to reflect the new statutory deadlines, instead SAAA issued a single page addendum to the Annual Governance and Accountability Return (AGAR) to the highlight these changes.
The various sector bodies have also published guidance you may find useful about the impact of Coronavirus as follows:
Please refer to our detailed instructions for 2019/20 document for further information.
Signing and submitting the AGAR forms
There are no changes in the requirement for wet signatures on the AGAR. Wet signatures need to be added to the AGAR in the same order as previous years and that the AGAR will need to be passed between the relevant individuals for signature. Where individuals are self-isolating it is hoped that local assistance will be available to facilitate this.
We set default submission deadlines for the receipt of the approved AGAR and supporting documentation or the Certificate of Exemption (as appropriate) – these are not the same as the statutory deadlines.
Parish meetings have been granted an additional month as they were only permitted to meet virtually from 1 August 2020. If you wish to extend your deadline to avoid receiving a chaser fee for late submission, please contact us – there is no charge to change the submission deadline.
The default submission deadlines are as follows:
- Parish meetings 1 September 2020
- All smaller authorities except parish meetings 31 July 2020
Non-submission by the deadline set for your authority will lead to chargeable chaser letters being issued (£40 plus VAT for all financially active smaller authorities). It is important to note, however, that in a change to prior years:
- no submission deadlines will be granted beyond 13 November;
- it will only be possible to extend submission deadlines by a maximum of 4 weeks at a time, providing sufficient justification explaining the need for the extension is given;
- a statutory recommendation will be issued to all financially active non-responding authorities that fail to submit their documents by 13 November. Statutory recommendations for non-response are charged at the standard fee rate depending on the authority’s expenditure banding and hence give rise to a minimum additional fee of £200 plus VAT.
IMPORTANT: If a financially active smaller authority is issued with a statutory recommendation (and/or a public interest report) for 2019/20, it will not be able to claim exemption from a limited assurance review for 2020/21, regardless of whether it meets all other criteria.
Our Small Body Assurance (SBA) team can be reached on firstname.lastname@example.org or +44 (0)20 7516 2200.