Navigating the New Wave: Understanding the AAF 01/20 Guidance for UK Tech Startups

A comprehensive analysis and commentary on the TECH 01/20 AAF and its significance to the UK tech startup landscape

3 mins read

Key Takeaways

  1. TECH 01/20 AAF is a new standard implemented by the ICAEW, meant to overhaul and update internal controls within service organisations.
  2. The guideline reshapes the language, concepts, and responsibilities of service organisations and service auditors.
  3. The transition from AAF 01/06 to AAF 01/20 aims to better align with the industry’s evolving risks and the widely recognised ISAE3402 and SSAE18 SOC1 regulations.
  4. AAF 01/20 presents unique opportunities and challenges for UK tech startups in terms of controls assurance, compliance, and governance over sub-service providers.
  5. Familiarity and preparation with respect to AAF 01/20 are essential for UK startups to maintain a competitive edge.


The dawn of the new decade brought with it significant regulatory updates. At the centre stage of these updates is the Assurance on internal controls of service organisations (TECH 01/20 AAF) issued by the Institute of Chartered Accountants in England and Wales (ICAEW) in January 2020. With the AAF 01/20 supplanting the previous AAF 01/06, there’s an urgent need for UK tech startups to acquaint themselves with this guidance for their first-time reports, as well as those transitioning from the old standard.

Understanding and implementing this guidance are vital for tech startups to foster a compliant and effective control environment. As Wade (2021) elucidates, this regulatory revamp seeks to increase clarity, consistency, and alignment with other recognised regulations.

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A Deeper Dive into AAF 01/20

Changing Terminology

In its bid to synchronise with ISAE3402 and SOC1, the AAF 01/20 guidance introduces a shift in language, with terms such as “control procedures” being replaced by “control activities”, and “reporting accountant” rechristened as “service auditor”. These tweaks, though superficial, represent a larger goal of international harmonisation of control standards and principles.

Control Objectives

The AAF 01/20 revamps the control objectives, moving away from the decade-old framework of AAF 01/06. The guidelines now offer more industry-specific illustrative control objectives that cover common risks and must be reported on as a minimum. This enhancement brings into focus the need for senior management to undertake independent assessments on the coverage of key risks in their organisation Allen, C. (2023).

The Role of Sub-service Organisations

The ICAEW’s new guidance underscores the service organisation’s responsibility for control activities, even those performed by sub-service providers. This point becomes pivotal in the context of UK tech startups as they frequently engage sub-service organisations for various services. Thus, disclosure requirements and governance over these sub-service providers form a significant part of AAF 01/20 compliance.

Removal of the Stewardship Code

The AAF 01/20 guidance marks the end of the UK Stewardship Code’s role in assurance reporting, a development that startups need to note. However, they can reference other reports relevant to users, thereby maintaining an informative approach.

Mandatory Management Statement

Replacing the former Director’s Report, a Management Statement is now obligatory under AAF 01/20. This statement must cover the purpose of the report, specific attestation over the fairness of the description, and the suitability of the service organisation’s control activities in meeting the control objectives.

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Increased Expectations on Service Auditors

With the introduction of AAF 01/20, service auditors face heightened expectations. Their review scope now extends to subsequent events and the accuracy of information provided by the service organisation. This change necessitates management to be more proactive and prepared for these additional tests.

Implications for UK Tech Startups

Table 1: Key Implications of AAF 01/20 for UK Tech Startups

Greater Compliance BurdenTech startups need to assess and adapt their current control activities and frameworks to meet the updated guidelines.
More Robust ReportingStartups are required to provide in-depth and comprehensive reports that demonstrate their compliance with the new standards.
Increased Management ResponsibilitySenior management now has more responsibility in terms of assessing and tailoring control objectives and activities.
Enhanced Governance Over Sub-service OrganisationsStartups engaging with sub-service organisations have an increased responsibility to oversee their control activities.

Key Steps for UK Tech Startups

Table 2: Key Steps for UK Tech Startups in Adopting AAF 01/20

Understand the ChangesStartups need to thoroughly understand the changes brought about by AAF 01/20 and how these impact their operations.
Assess the Current Control FrameworkThe next step is to analyse the current control framework to identify gaps and make changes to meet the new guidelines.
Update Control Objectives and ActivitiesBased on the assessment, startups need to update their control objectives and activities to comply with AAF 01/20.
Prepare a Comprehensive Management StatementIt’s crucial to prepare a comprehensive management statement that covers all the necessary areas.
Strengthen Sub-service Organisation GovernanceStartups need to enhance their governance over sub-service organisations to meet the new requirements.
Engage Service AuditorsLastly, startups should engage service auditors to verify their compliance with the AAF 01/20.


As the UK tech startup landscape continues to evolve, regulatory compliance cannot be overlooked. Understanding and implementing the AAF 01/20 guidance is a key step towards building a robust control environment that not only fosters confidence among stakeholders but also aligns with industry standards.

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Taking steps to integrate the AAF 01/20 guidance into their controls framework is necessary for startups to not only maintain their edge but also shape a resilient future. The ICAEW offers extensive resources to support these transitions, and engaging with experts can provide the necessary insights and support in this new era of assurance. As the tech industry is always about the next big thing, it’s only fitting that UK startups look ahead and embrace the changes brought about by the AAF 01/20. After all, a startup’s success may well hinge on its capacity to navigate the new wave of regulatory demands.

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