Accountant vs. Bookkeeper: Different KYC Requirements
Accountant vs. Bookkeeper: Different KYC Requirements
"But I just do bookkeeping - do I really need to check all that?" The question often comes from bookkeepers who discover they're also covered by the AML law. And the answer is: Yes, but not in the same way as accountants.
Let's cut through the confusion and see exactly what the law requires from whom - and why the differences actually make good sense.
Fundamentally: Both Are Covered
First the important part: Both accountants and bookkeepers are covered by the AML law when they:
- Provide tax advice
- Assist with business establishment
- Handle client funds
- Act as nominees/nominal owners
But the depth and scope of KYC requirements vary significantly.
The Accountant's Enhanced Responsibility
As an accountant, you have the heaviest responsibility:
Statutory Audit = Highest Requirements
- Full due diligence on all clients
- Comprehensive documentation
- Enhanced monitoring duty
- Direct responsibility for deficiencies
Attestation Services
- Review and assistance also require full KYC
- You put your stamp = your responsibility
- No "light" version allowed
Advisory Services
- Tax optimization = full KYC
- Business structures = extra attention
- M&A activities = highest risk level
Bottom line: As an accountant, you can't escape. Full KYC every time.
The Bookkeeper's Proportional Duties
As a bookkeeper, the picture is more nuanced:
Pure Bookkeeping = Minimal KYC
If you ONLY:
- Record receipts
- Prepare VAT returns
- Produce balance/income statements
...then your KYC requirements are limited to basic identification.
But Watch the Boundaries!
As soon as you:
- Advise on VAT optimization
- Help with tax deductions
- Suggest deductions
- Assist with tax returns
...you step into the advisor role and KYC requirements increase significantly.
Practical Differences Illustrated
Scenario: New Client - Local Shop
Accountant must:
- Verify owner via passport + MitID
- Investigate entire ownership chain
- Risk assess the industry
- Establish ongoing monitoring
- Document everything
Bookkeeper (pure bookkeeping) must:
- Verify company existence (CVR)
- Note contact person
- Basic documentation
Scenario: International Company
Accountant must:
- Full mapping of group structure
- Verify ultimate beneficial owners
- Investigate transfer pricing
- Extra documentation on money flows
Bookkeeper should:
- Consider whether they can take on the task
- If yes: Almost same level as accountant
- Often better to refer to accountant
The Legal Gray Zone
Here it gets tricky. Many bookkeepers operate in the gray zone between pure bookkeeping and advisory:
"Shouldn't that expense go on account 3120?"
- Technical bookkeeping = OK with basic KYC
- But if it affects tax = advisory
"You can save VAT by..."
- Clearly advisory = full KYC required
"The accountant usually..."
- Reference to practice = OK
- Own recommendation = advisory
Risk Assessment: Different Approaches
Accountant's Risk Assessment
Must include:
- Detailed industry assessment
- Geographic risk analysis
- Complexity in structure
- Transaction patterns
- PEP and sanctions lists
Bookkeeper's Risk Assessment
Can often suffice with:
- Simple industry assessment
- Cash vs. non-cash
- Local vs. international
- Normal vs. unusual activity
Documentation Requirements
Accountant: Everything must be documented. No exceptions. 5-year retention. Full audit trail.
Bookkeeper: Proportional documentation. Basic info must be saved. Focus on essentials.
But remember: "Proportional" doesn't mean "optional"!
Inspection and Consequences
When the Business Authority Comes
At accountant: Full review. Samples in all areas. Strict documentation requirements.
At bookkeeper: Focus on whether you stay within your area. Check of basic compliance.
Sanctions
Accountant: Fines from 50,000 DKK and up. Risk of license revocation.
Bookkeeper: Typically lower fines. But for gross violation: Same level.
Practical Tips for Both
For Accountants
- No shortcuts - full KYC always
- Invest in systems
- Document everything
- Train all employees
For Bookkeepers
- Define your services clearly
- Stay away from advisory without full KYC
- Refer complex cases
- Document your delimitation
Collaboration Creates Value
The smartest solutions come when accountant and bookkeeper collaborate:
Bookkeeper: Handles daily bookkeeping Accountant: Takes advisory and complex assessments
Benefits:
- Clear division of labor
- Appropriate KYC level
- Efficient resource utilization
- Less risk for both
The Future: More Clarity Coming
The industry is working on:
- Clearer guidelines
- Better delimitation
- Standardized procedures
- Technological solutions
But until then: Better be on the safe side.
Conclusion
The difference between accountant and bookkeeper KYC requirements is about responsibility and risk. Accountants have full responsibility and therefore full requirements. Bookkeepers can often manage with less - if they stick to pure bookkeeping.
But beware: As soon as you advise, requirements increase drastically. And "I didn't know" doesn't hold in court.
So know your role, know your limits, and build your KYC system accordingly. Because ultimately, it's about protecting both yourself and your clients.
