Accountant's Terms of Business (Malta Template)
Updated on 6 August 2026
This is a terms of business template for a Malta accountancy practice: a general part that governs the whole relationship, alongside optional service schedules where you tick only what the practice actually does. What isn't ticked isn't in scope — and that is the single most important sentence in the document.
The template is written for Malta's particular shape: the CPA warrant that gatekeeps the title "accountant" in a way most markets don't have, the six-week VAT return cycle under Article 10, the CFR tax representative registration that is separate from — and doesn't automatically follow — the engagement itself, and a retention regime that runs two different clocks depending on whether the question is company law or VAT. Fill in the fields and download a clean Word or PDF file, no sign-up required.
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Terms of Business
These are the terms of business of , version , effective from . They form an integral part of the engagement for accountancy services.
- Practice:
- CPA warrant holder responsible:
- Address:
- Client:
- , VAT number
- Client address:
- Client contact:
- Date of agreement:
- First accounting period covered:
1. Warrant status
The engagement is carried out under the responsibility of , holder of a warrant issued under the Accountancy Profession Act. confirms that its registration with the Accountancy Board, including the annual return due by 31 January each year, is current.
2. Scope of engagement
This engagement covers only the services for which a schedule appears below. Services not listed are not within scope, and their deadlines are not monitored by the practice. Extending the engagement requires written agreement; the new schedule then becomes part of this document.
Services are performed on the basis of records and information supplied by the client. Responsibility for their accuracy and completeness rests with the client, and the client's own statutory obligations remain the client's.
3. Bookkeeping
The practice maintains the books on the basis of records supplied by the client, and issues agreed reports. Records for the relevant period are due . Records delivered later are processed in the following period unless otherwise agreed.
4. Annual financial statements
Financial statements are prepared . Approval remains the responsibility of the client's governing body; the practice does not sign the financial statements on the client's behalf.
5. Audit is not included
This engagement does not include a statutory audit or any other assurance engagement, and does not provide the assurance an audit would give. If the client requires or becomes subject to audit, appointment of an auditor and the terms of that engagement are arranged separately.
6. Income tax
The income tax return is filed by . The client reviews the return before filing. Filing requires a valid CFR authority to act; its absence prevents timely filing.
7. VAT
. Article 10 registrations under the Value Added Tax Act file returns within six weeks following the end of each VAT quarter, and returns are filed online through CFR VAT e-Services. Supporting documents for the period are due from the client .
8. VAT accounting basis for this engagement
VAT is accounted for on the standard accrual basis.
9. Client responsibilities
The client supplies records within the deadlines set out in the service schedules, is responsible for the accuracy and completeness of the information, and notifies the practice of changes to the business that affect its accounts, tax position, or filing obligations.
Services tied to statutory deadlines depend on records being supplied in time. Where records are delivered late, the practice will do what is reasonably possible within the time remaining but is not responsible for missing a statutory deadline or the consequences of doing so.
10. Fees and invoicing
Fees are a fixed monthly amount of , plus VAT, for the services ticked above. The fee is based on an assumed volume of transactions and staff; a material change in these assumptions is reviewed jointly before a revised fee takes effect.
Fees do not include: . Such work begins only once scope and price have been agreed.
Payment is due within days of the invoice date. Late payment may attract interest at the statutory rate.
11. CFR representation
This engagement requires the following CFR registrations: . None of these authorities is created by signing this document; each must be registered separately through CFR Services.
CFR registrations do not expire automatically when this engagement ends and must be dealt with separately at that time. Where the client changes accountant, the incoming practice should have its own registration in place before the outgoing practice's registration is treated as closed, to avoid a period in which no one has authority to file.
12. Record retention
Form and location of records: . Records the client has supplied remain the client's property. The practice's own working papers, calculations and internal notes remain the practice's property.
Under the Companies Act, accounting records are kept a minimum of ten years at the registered office. VAT records, including invoices, are generally retained a minimum of six years from the end of the relevant year, and certain transactions conducted in Malta may require retention of up to ten years. On termination, client records held by the practice are available for collection within days.
13. Anti-money laundering measures
The practice is subject to applicable anti-money laundering and counter-terrorist financing obligations. The client supplies information required for identification and due diligence, details of ownership structure and beneficial owners, and notifies changes to these. The obligation arises by law and does not depend on the client's consent.
14. Limitation of liability
The practice's liability under this engagement is limited to per event and in aggregate for losses arising from the same cause. This limit does not apply to fraud or to liability that cannot lawfully be limited.
The practice is not liable for loss arising from inaccurate or incomplete information supplied by the client, late delivery of records, or the absence of a valid CFR authority to act. Work is prepared for the client and does not create obligations to third parties to whom the client provides it.
15. Confidentiality
Information obtained in the course of this engagement is confidential and is not disclosed without the client's consent, except where required or permitted by law. Confidentiality continues after termination.
Subcontractors and IT service providers bound by an equivalent duty of confidentiality may be engaged to perform services; responsibility to the client remains with the practice.
16. Data protection
In connection with payroll and other services, the practice processes personal data on the client's behalf and in accordance with its instructions. The subject matter, duration, security measures, and return or deletion of data on termination are governed by a separate data processing agreement.
17. Duration and termination
This engagement is for an indefinite term, effective from the start date. Either party may terminate it in writing with days' notice.
On termination, the parties agree, service by service, the period and deadline up to which the practice is responsible for performance. This is necessary in particular for VAT, whose six-week cycle is shorter than most notice periods.
On non-payment, the practice may suspend work after notice. Client records are not withheld to force payment nor in a manner that would prevent compliance with a statutory deadline.
18. Governing law and disputes
This engagement is governed by the law of Malta. The parties will attempt to resolve disputes amicably; failing that, the forum is .
Acceptance
Signatures confirm acceptance of these terms and of the service schedules ticked above. Services not ticked are not within scope.
For the practice
Date:
For the client
Date:
The CPA warrant gatekeeps the title, and the Accountancy Board has its own annual deadline
A "Certified Public Accountant" in Malta holds a warrant issued under the Accountancy Profession Act, and use of that title without one is not simply a courtesy breach — it is the difference between a regulated practitioner and someone who isn't. A firm's terms of business should state the warrant holder's name plainly, not just the practice's trading name, because it is the warrant that carries the professional standing and the indemnity requirements behind it.
Separately from anything owed to a client, warrant holders and accounting or audit firms must submit an annual return, together with the annual registration fee, to the Accountancy Board by 31 January each year. This is a standing obligation of the practice, not something the terms of business need to describe to the client — but a practice that lets it lapse is not entitled to describe itself as a current warrant holder, which is exactly the kind of gap a client has no way to check.
Terms of business built from a template designed for an unregulated bookkeeping market will typically say nothing about warrant status at all. In Malta, that omission matters.
VAT runs a six-week cycle under Article 10 — shorter than it looks at first glance
Article 10 VAT registrations file quarterly, but the filing window is six weeks following the end of each VAT quarter, not one month. Mandatory online filing through the CFR VAT e-Services has applied to all VAT returns due on and after 15 February 2023.
Six weeks sounds generous next to a monthly cycle elsewhere, but it is the shortest statutory clock in this engagement once the quarter itself is accounted for, and a terms-of-business document that only says "VAT quarterly" without stating the six-week filing window invites a client to assume more slack than the law actually gives.
Where professional services are supplied by a warrant holder, VAT is accounted for on a cash basis rather than an accrual basis — a mechanic specific to warrant-holding professions that a general VAT clause borrowed from another market won't capture.
CFR representation is registered separately, and doesn't transfer with a new engagement letter
Acting for a client online through CFR Services requires registration as a tax practitioner using the CFR01 form, or appointment as a registered tax representative (CFR02) or registered user (CFR03) to file VAT returns on the client's behalf. None of this is created automatically by signing an engagement letter, and none of it lapses automatically when one ends.
The practical consequence for a change of accountant: the incoming practice needs its own CFR registration before it can file anything, and the outgoing practice's registration needs to be dealt with separately rather than assumed to expire on its own. Terms of business and disengagement documents should treat this as its own line item, not fold it into a general "authority to act" clause.
The order matters in the same way it does elsewhere in this series: get the incoming practice's registration in place before treating the outgoing one as closed, so there is no window where nobody can file.
Two retention regimes, not one
Under the Companies Act (Chapter 386), accounting records are kept for a minimum of ten years at the registered office or such other place as the directors think fit, and must be open to inspection by the company's officers at all times. That is a company-law obligation, independent of tax filings.
VAT records, including invoices, are generally retained for a minimum of six years from the end of the year to which they relate, though the period for transactions conducted in Malta can extend to ten years in some cases. A firm that quotes only one of these two figures — treating "records" as a single undifferentiated category — is describing neither regime completely.
Terms of business should therefore separate the two: company-law records held ten years at the registered office, and VAT records held at least six years and potentially longer, with the practice stating plainly which of the two it is describing at any given point.
Clauses explained
- Warrant status
- Names the CPA warrant holder responsible for the engagement, distinct from the practice's trading name, and confirms current registration with the Accountancy Board.
- Scope of engagement
- The engagement is limited to the ticked service schedules; unticked services are not in scope and their deadlines are not monitored.
- Service schedules
- One optional schedule per service: bookkeeping, annual financial statements, income tax, VAT, payroll, company secretarial filings, advisory.
- VAT
- States the applicable VAT period and the six-week filing window under Article 10, and whether professional-services cash accounting applies.
- Client responsibilities and deadlines
- Document-delivery deadlines for each service, responsibility for accuracy of information, and consequences of late delivery for statutory deadlines.
- Fees and invoicing
- Hourly rate, fixed monthly fee, or fixed fee for defined scope, each with a list of excluded work and a payment term.
- CFR representation
- Which CFR registrations the engagement requires — tax practitioner, registered tax representative, or registered user — and confirmation that none of these is created by signing this document.
- Record retention
- Separates the ten-year company-law retention period from the VAT retention period of at least six years, and states who holds the records.
- Anti-money laundering measures
- Client identification and due diligence, updating of information, and that the obligation arises by law rather than by the client's consent.
- Limitation of liability
- A capped figure, exceptions to the cap, and confirmation that the work is prepared for the client and does not create obligations to third parties.
- Confidentiality and data protection
- Confidentiality continues after termination, and personal data processing is governed by a separate agreement.
- Duration and termination
- Notice period for either party, suspension of work after notice for non-payment, and fixing the cut-off date for each service on termination.
- Governing law and disputes
- Maltese law and the forum for disputes.
- Acceptance
- Signature block that turns the terms into an agreement rather than a document merely sent.
What not to overlook
Check current guidance and your own insurance cover before use.
Name the warrant holder, not just the practice
Use of the title "Certified Public Accountant" requires a warrant under the Accountancy Profession Act. Warrant holders and accounting or audit firms must submit an annual return with the registration fee to the Accountancy Board by 31 January each year; terms of business should name the responsible warrant holder.
Accountancy Board — annual return for CPA warrant holdersState the six-week VAT filing window, not just "quarterly"
Article 10 VAT returns are due within six weeks following the end of each VAT quarter, and mandatory online filing through CFR VAT e-Services has applied since 15 February 2023. A clause that says only "VAT quarterly" understates how tight the actual filing window is.
Malta Tax and Customs Administration — VAT return cycleTreat CFR representation as its own registration
Filing online on a client's behalf requires registration as a tax practitioner (CFR01), or appointment as a registered tax representative (CFR02) or registered user (CFR03). None of this is created by an engagement letter and none lapses automatically when one ends — get the incoming practice's registration in place before treating the outgoing one as closed.
CFR Online Services — registration and appointment formsSeparate company-law retention from VAT retention
Accounting records are kept a minimum of ten years at the registered office under the Companies Act, while VAT records including invoices are generally retained a minimum of six years from the end of the relevant year, with some transactions extending to ten years. Terms of business should state which regime applies to which document set.
Be.Legal Malta — record-keeping obligationsDon't withhold client records instead of suspending work
On non-payment, the correct tool is to suspend work after notice. Records the client has supplied are the client's property; the practitioner's own working papers remain the practitioner's property. Withholding records just before a VAT or tax filing deadline moves a fee dispute onto ground where the practice cannot win.
How to prepare the terms
- Name the warrant holder. State the CPA warrant holder responsible for the engagement and confirm current Accountancy Board registration.
- Tick only the services actually engaged. Each service has its own schedule. Unticked services are explicitly excluded, and their deadlines are not monitored.
- State the VAT period and the six-week filing window. Article 10 returns are due within six weeks of quarter end — shorter than a generic "quarterly" clause implies.
- List the CFR registrations the engagement requires. Tax practitioner, registered tax representative, or registered user — and confirm none is created by this document alone.
- Set fees and the liability cap. Choose a fee model, state what's excluded, and express the liability limit as a figure.
- Download, sign, and keep. Download the Word or PDF file, obtain a signature before work begins, and keep the signed copy with the client file.
Frequently asked questions
Does a Maltese accountant need a warrant?
To use the title Certified Public Accountant, yes — a warrant is issued under the Accountancy Profession Act, and warrant holders and accounting or audit firms must submit an annual return with the registration fee to the Accountancy Board by 31 January each year. Terms of business should name the responsible warrant holder rather than just the practice's trading name, since it is the warrant that carries professional standing.
How often is VAT filed in Malta, and what's the actual deadline?
Article 10 registrations file quarterly, but the filing window is six weeks following the end of each VAT quarter, not simply the next month. Mandatory online filing through CFR VAT e-Services has applied to all returns due on and after 15 February 2023. A clause that says only "quarterly" without the six-week window understates how tight the deadline is.
Does a new engagement letter automatically give my accountant authority to file with CFR?
No. Filing online on your behalf requires separate registration — as a tax practitioner (CFR01), or as your registered tax representative (CFR02) or registered user (CFR03). Signing an engagement letter doesn't create this authority, and it doesn't lapse automatically either; it needs to be dealt with as its own step when changing accountant.
How long must accounting records be kept in Malta?
It depends which regime applies. Company-law accounting records are kept a minimum of ten years at the registered office under the Companies Act. VAT records, including invoices, are generally retained a minimum of six years from the end of the relevant year, though certain transactions conducted in Malta can extend to ten years. Terms of business should state which figure applies to which document set rather than quoting a single period for everything.
Is VAT accounted for on a cash or accrual basis for professional services?
Where professional services are supplied by a person holding a warrant issued under Maltese law to practise that profession, VAT is accounted for on a cash basis rather than an accrual basis — a mechanic specific to warrant-holding professions that a generic VAT clause borrowed from elsewhere won't capture.
Can an accountant withhold my records until I pay an outstanding invoice?
The correct tool on non-payment is to suspend work after notice, not to withhold records. Records the client has supplied are the client's property; the practitioner's own working papers, calculations and internal notes remain the practice's property. Withholding records just before a VAT filing deadline moves a fee dispute onto ground where the practice cannot win.
Does this engagement include a statutory audit?
Only if separately agreed with an auditor, and preparing accounts or financial statements does not itself provide the assurance an audit gives over the same figures. The template has a separate optional clause for this, because clients often assume otherwise.
Related templates
Disclaimer
This template and guidance are general information and do not constitute legal or accounting advice. Rules on the accountancy profession, VAT, CFR registration, and anti-money laundering obligations change, and requirements depend on the nature of the business. Check current guidance and your own insurance cover before use, and seek professional advice in the event of a dispute.
