I agree with what you say Liz, but I also think it can be even more messy if you practise without the right level of insurance and ICB membership.
If you set up a practise at Level 2, you can get PI and a practise license. The PI covers you for bookkeeping, it doesn't appear to be more detailed than that. But your ICB membership only covers you to do sole traders and not Ltd companies.
If you then went ahead and did the books for a Ltd company, I'm not sure how your PI stands if you made an error, insurance companies never pay if they can wriggle out of it.
But the real issue is as you say MLR, because the ICB do not cover you for Ltd companies at Level 2. Regardless of if you make an error or not you are breaking the MLR because as a bookkeeper you must be registered either directly with hmrc (which is quite costly) or through a supervisory authority such as the ICB.
The thing is not to confuse Indemnity Insurance with the ICB, Insurance covers you if you make errors which costs your client. Whearas the ICB registers your practise under MLR. I'm not sure what the penalty is for working as a bookkeeper without being registered under MLR but I'm sure it would involve some kind of fine and being banned from practising as bookkeeper by hmrc.
Mike
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