Why U.S. Accountants Still Cannot Practice in the U.K.

“If it ain't broke, don't fix it”, but when you try fixing what's already working (sorta), you'd better bring a good wrench. And right now, it seems like the US and UK can't agree on whose toolkit to use. Talks that aimed to let American and British accountants audit across the pond with less red tape have stalled, again. What began as a promising pilot program in 2018 between the US and Scotland has fizzled, leaving top firms, regulators, and a lot of bean counters scratching their heads. So, what went wrong? And why should finance professionals on both sides of the Atlantic care?

It All Started with a Pilot

Back in 2018, the Institute of Chartered Accountants of Scotland (ICAS) and the American Institute of Certified Public Accountants (AICPA) launched a pilot program to recognize each other's audit qualifications. The goal? Give top auditors a fast lane to practice in each other's countries, perfect for handling complex audits of banks and companies listed in both the US and UK. The pilot even got two extensions and seemed to be heading somewhere. But last year, it was quietly grounded. Bruce Cartwright, CEO of ICAS, diplomatically called the process “suspended, not ended.” That’s like saying your favorite restaurant didn’t close, it just hasn’t served food in a year.

Paperwork vs. Practice

At the heart of the stalemate? Training standards. The UK plays it strictly when it comes to audit qualifications. Do you want to sign off on a company’s financials? Better clock those extra hours of training and hands-on experience. In the US, things are a bit more relaxed. CPAs still train hard, but there’s less micromanaging of specific audit experience. And therein lies the rub: the UK wants proof that US auditors meet its exacting standards, but there’s no agreed way to measure that.

Cartwright summed it up perfectly: “We couldn’t get to an agreement on what hurdles we would need.” Translation: both sides brought hurdles, but no one brought a tape measure. The AICPA, on the other hand, is asking for equal treatment. Their stance? “We expect the same consideration for US CPAs that we offer to be licensed accountants from other countries.” Fair ask, but the UK’s audit rules aren’t exactly plug-and-play.

ACCA Gets the Cold Shoulder

If training standards weren’t tricky enough, the guest list for negotiations has also stirred the pot. While the AICPA has been cozying up to ICAS and the Institute of Chartered Accountants in England and Wales (ICAEW), the third major UK body, the Association of Chartered Certified Accountants (ACCA), hasn’t been invited to the party. That’s awkward, considering ACCA has the second-largest membership in the UK.

ACCA made it clear that no deal is final without the Financial Reporting Council’s (FRC) stamp of approval, and any deal the FRC signs off on would apply to all UK bodies, not just the chosen few. It’s like throwing a block party and forgetting to tell half the neighborhood. Now nobody’s playing nicely. The FRC’s role ensures that quality and consistency are upheld across the board. It sets and enforces audit qualification standards, meaning it must vet any cross-border recognition arrangement to ensure it aligns with UK audit oversight rules. Until the FRC signs off, everything else is just wishful thinking.

The Big Four Have Skin

Deloitte, EY, KPMG, and PwC are watching this saga unfold with growing concern. These firms have a global footprint, and cross-border audits are their daily bread. Being able to move staff freely between the US and the UK isn’t just convenient, it’s crucial. One senior exec at a Big Four firm in the UK even said that the free movement of accountants is essential for smooth audits, especially when companies are listed on both exchanges. Cartwright echoed the sentiment: “We shouldn’t underestimate the complexity of these big financial institutions.” When you've got audit rockstars in the US, why not let them shine in London, too?

Parliament Tries to Play Referee

Even though the deal is stalled, the UK government isn’t throwing in the towel. In March 2025, it proposed updates to the Companies Act, basically giving UK bodies the green light to count foreign audit experience (like that of a US CPA) toward their qualifications. It's a solid move to grease the wheels for future recognition deals. Think of it as building a better ramp, even if the road isn’t quite finished. The proposed amendments also aim to sync with the Professional Qualifications Act 2022, creating room for mutual recognition agreements beyond just the EU club.

Final Word

Not quite. “Suspended” means there’s still hope. But let’s be real, it’s going to take more than polite emails and good intentions to revive it. The challenge now is aligning two very different systems, each with its own logic and legal backbone. But the incentives are huge: more flexibility for firms, better job opportunities for professionals, and a stronger transatlantic audit network. If the accounting world wants to keep up with the fast-paced global economy, it’ll need to figure out how to move people as smoothly as capital. For now, accountants dreaming of a seamless move between the US and UK will have to wait. But with major firms pushing for progress and governments updating the rulebooks, there’s reason to believe this deal could get back on track. Just don’t expect it to happen overnight. Or as we say over here, don’t count your chickens before they pass the audit. Be the first to know with fresh insights from our newsletter!