Association of Accounting Technicians response to Small Business, Enterprise and Employment Bill: Duty to report on payment practices and policies

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1 Association of Accounting Technicians response to Small Business, Enterprise and Employment Bill: Duty to report on payment practices and policies 1

2 Association of Accounting Technicians response to Small business, enterprise and employment bill: duty to report on payment practices and policies 1. Introduction 1.1. The Association of Accounting Technicians (AAT) is pleased to have the opportunity to respond to the consultation paper on Small business, enterprise and employment bill: duty to report on payment practices and policies, released on 27 November 2014 (condoc) AAT is submitting this response on behalf of our membership and from the wider public benefit of achieving sound and effective administration of taxes While not addressing all areas that are included in the consultation, AAT has commented where we believe we can add value or highlight aspects that need to be considered further. AAT has focussed on the operational elements of the proposals and have provided opinion on the practicalities in implementing the measures outlined. Furthermore, our comments reflect the potential impact that the proposed changes would have on SMEs and microentities, many of which employ AAT members or would be represented by our operationally skilled members in practice Many 1 AAT Members in practice (MIPs) have clients who are affected by issue of late payment. 2. Executive summary 2.1. AAT recognises that the culture of late payment remains a significant problem for UK businesses, particularly small and micro entities. Whilst recognising the effect that large firms have on supply chains, AAT has a clear desire for greater transparency around payment practices, with a view towards a change in culture and welcomes the proposal for a new reporting requirement on prompt payment practices AAT welcomes the fact that the reporting requirements are not placing a burden on small businesses The scale and impact of late payment in the UK, outlined in Annex B to the condoc, states Research undertaken by BACS suggests that 60% of businesses have experienced late payment and the late payment debt burden borne by UK business has increased to 46.1bn. It also suggests that the late payment debt burden borne by UK SMEs is significantly larger than for corporates; 39.4bn compared to corporates who are owed 6.7bn at any one time. A survey undertaken by the Federation of Small Businesses on its members confirms the level of late payment, with 5 in 10 SMEs feeling they were paid late by a large company. AAT is concerned for the long term impact of the imbalance of the late payment debt burden borne by SMEs and their future sustainability, and welcomes the proposed Duty to Report on Payment Practices and Policies. 1 AAT has over 4,100 MIPs (as of 31 Dec 14) who collectively represent the interests of approximately 300,000 clients and we would estimate that a significant number of these clients will be affected by the issue of late payment. 2 BACS article UK companies face a late payment burden of 46.1bn 2

3 2.4. AAT concurs with the concern (7.19, condoc), that rising payment length is starting to cause cashflow problems. A proposal to identify where businesses are extending their payment terms to benefit from the additional cashflow at the expense of their suppliers, is welcomed The uncertainty of late payment is still the biggest issue for suppliers and it is hoped that these metrics will highlight those companies aiming to pay promptly, both on time and to shorter terms It is widely accepted that previous attempts to legislate to bring greater openness and transparency to the payment practices of companies, large companies specifically, has on the whole been ineffective. Whilst The Prompt Payment Code was set up by the Institute of Credit Management in 2008, to promote a culture of prompt payment, it is a voluntary measure and to date only 1,755 companies have signed up to the Code AAT supports a mandatory approach of a Duty to Report on Payment Practices and Policies, together with the introduction of penalties for non-compliance. 3. AAT response to the consultation paper on Small Business, Enterprise & Employment Bill: Duty to report on payment practices and polices 3.1. The following paragraphs outline AAT s response to the proposals outlined in the consultation paper. AAT has listed the questions and its response to those questions. Where AAT has declined to comment, this is stated accordingly. Question 1 Do you agree that the reporting requirement set out in this document is clear and easy to understand? 3.2. AAT agrees that the reporting requirement set out in this document is clear and easy to understand The document addresses the fact that a mandatory reporting requirement for larger companies will potentially have the biggest impact on reducing the debt burden of SMEs It also provides recognition that more transparency is required for suppliers, in terms of standard payment terms and actual payment practices The document provides a clear indication of the utmost importance for a supplier to understand the process that a dispute with a company will go through, or who will help if a dispute is ongoing for a significant period. Question 2 Do you agree that the reporting requirement should effectively only cover payments related to business to business contracts? 3.6. AAT acknowledges and agrees with the view (7.1, condoc) that the reporting requirement should only cover payments related to business to business contracts as it has the biggest impact on small and micro entities It is recognised that the cost of delayed payments is ultimately passed on to consumers. 2 Figure accurate as at 30 January

4 Question 3 Do you agree that we should be excluding financial services contracts? If yes, which financial services should we exclude; and how should we define them? 3.8. AAT has no comment on whether financial services contracts should be included or excluded. Question 4 Do you agree that the reporting requirement should extend to (a) large UK companies (b) large LLPs and (c) all quoted companies? 3.9. AAT recommends that the reporting requirements should extend to large UK companies, large LLPs and all quoted companies for the reason given that late payments are more prevalent in larger organisations (7.3, condoc) AAT recommends that the reporting requirements should be extended to include medium sized companies It is recognised that large sole traders and partnerships may not be caught by the reporting requirements e.g. The John Lewis Partnership or mutual organisations. Therefore, AAT recommends that as part of this consultation, consideration should be given to addressing this issue. Question 5 Do you agree that the Companies Act provides an appropriate threshold of whether a private company or LLP qualified for an exemption from reporting? AAT supports the proposal that all businesses within scope should be required to report at an individual company level. It is recommended that medium sized companies, as suggested at 3.10 (above) should also be required to report Under the current reporting framework, groups are required to report on a consolidated basis rather than a business-by-business approach. Whilst acknowledging that group level reporting reduces costs, AAT recognises the need to know of the health of the individual business customer which is a key factor in negotiations or deciding to trade with someone AAT recommends that the success of the reporting requirements should be reviewed in three years. If successful, consideration should be given to expanding the reporting requirements to include smaller companies. Question 6 Do you agree that businesses should be required to provide individual and nonconsolidated report on their payment practices AAT supports the proposal that the content of a report (7.6, condoc) should be aimed at giving suppliers the information they need to make informed decisions about the payment practices of customers they are entering into business with. AAT approves of the example of what the report might look like and the information requirements AAT endorses the view expressed at 7.7 (condoc) that it is important that suppliers understand when to expect payment from a customer-firm, and whether the customer is likely to extend payment terms in the near future. The proposal that the reporting requirements should include a description of the firm s standard payment terms is supported by AAT. We consider that this will allow suppliers to judge whether they are being offered terms less favourable than other suppliers, and how this compares against an industry average. 4

5 3.17. AAT agrees that a standard term should be one that is used in most contracts (7.8, condoc). If there is no standard on this basis, an alternative proposal that could be that the average of all payment term lengths, is supported AAT considers that knowing the maximum payment terms employed will aid suppliers in understanding why they are offered such terms. Where the terms differ significantly from standard terms offered, or an industry norm, a supplier will be better informed and potentially in a position to negotiate more appropriate terms AAT can report on an anecdotal basis the experiences encountered by some MiPs and employed members who have expressed the view that, in recent years, they have experienced a rising number of complaints over large companies altering their payment terms at short notice, even on occasions retrospectively and without consultation with their suppliers (7.10, condoc). Question 7 Do you agree that businesses should report on (a) their standard (b) their maximum payment terms, and (c) any changes to these over the last reporting period? Should the report require information on whether suppliers had been notified or consulted on this change in advance? AAT supports the proposal for a mandatory requirement to report (7.11, condoc) and concurs that a voluntary approach to this report requirement would not work. The view (7.11, condoc) that poor performing companies would not wish to report and that probably only a limited number of highly performing companies would actually choose to report is a view AAT endorses AAT further supports a mandatory approach for all businesses in scope to report on their payment performance in a standardised way. AAT believes that such an approach will ensure that the worst performing businesses provide information on their payment performance in order to reduce their opportunity to gain a competitive advantage against peers who may choose to voluntarily report (7.12, condoc) The proposed reporting requirement on payment terms will assist suppliers in deciding whether to trade with a potential customer (3.13, above). Question 8 Do you agree that this report should be a mandatory requirement for all companies in scope? AAT agrees that this report should be a mandatory requirement for all companies in scope, as a key aim of this reporting requirement is to help identify the ability or willingness of a business to meet its payment commitments in commercial transactions, and it is proposed that the reporting requirement includes three different metrics that apply over the reporting period, in order to provide a better picture of the firm s payment practices, (7.15, condoc). Question 9 Do you agree that the reporting requirements should specify when the clock starts on the payment period? Do you agree that date of invoice is a suitable point to start the clock on payment? In terms of how to decide when the clock starts in respect of a payment period, In the absence of an extant service level agreement, AAT recommends that the date of supply is used, in line with VAT guidelines, i.e. for goods; the date they are sent, collected or made available, and for services; the date the work is finished. Question 10 Do you agree that a metric of invoices paid beyond terms should be included in this report? If yes, should this be for (a) proportion of invoices (b) value of invoices (c) both the proportion of invoices and the value of invoices? 5

6 3.25. AAT does not consider that the proposal to record these metrics as a percentage (rather than value) of all invoices paid in the reporting period that were paid later than 30, 60 and 120 days, as being the best way to inform suppliers. AAT recommends that reporting includes both percentage and value (7.20, condoc), to reduce the opportunity for information to be skewed AAT does not consider that adopting the approach outlined in 3.25 (above) would incur a disproportionate amount of administrative time in achieving compliance. Question 11 Should a business have to report on the average time taken to pay invoices? Does this add a valuable counter balance to the proportion of invoices paid to terms? AAT welcomes the inclusion of the average length of time taken to pay an invoice, measured by days, as part of the reporting requirements as this adds a valuable counter balance to the proportion of invoices paid to terms The requirement to report on the proportion of invoices paid beyond terms, will allow suppliers to plan for any additional costs that will be incurred, where a company is failing to meet its commitments regularly. AAT agrees that the reporting requirements should be against the proportion of invoices paid beyond terms during the reporting period, rather than the value of invoices, (7.17, condoc) Question 12 Would metrics demonstrating how many invoices are paid in (i) 30 (ii) 60 and (iii) 120 (iv) over 120 days be valuable to suppliers? If yes, should this be for (a) proportion of invoices (b) value of invoices (c) both the proportion of invoices and the value of invoices? AAT recommends that the intended metrics should include, both, the proportion of invoices and the value of invoices paid in 30, 60, 120 and over 120 days. A wider range of information will provide suppliers with a clearer picture in terms of deciding whether to trade with someone, as referenced at 3.13 (above). Question 13 Do you agree that it would be useful for the report to include additional information, in narrative form, to give suppliers an understanding of a firm s wider payment? Additional information in narrative form would provide companies with an opportunity to explain any variances to the normal. It would provide a right to reply. Question 14 Do you agree that it would be beneficial for a business to report on their existing dispute processes? AAT recognises that disputes are a standard practice among companies, and agrees that it is of the utmost importance that it is clear for a supplier to understand the process that their dispute will go through or even who will help if a dispute is on-going for a significant period of time (7.23, condoc) AAT agrees with the proposal that firms should be required to outline their dispute resolution processes, and recommend that the details are published on company websites. Question 15 Would it be helpful for the Government to provide a definition of a disputed invoice in the report? AAT agrees that it would be helpful for HM Government to provide a definition of a disputed invoice in the report. 6

7 Question 16 Have you experienced companies disputing invoices as a way of delaying payments? Do you see a role for Government intervention on this issue, and if so, what is it? It is recognised that some firms are using disputes as a method of delaying payment. Whilst the Late Payment of Commercial Debts (Interest) Act 1998 already sets an effective maximum standard quibble time for the acceptance and verification of goods and services of 30 days, after which a business can claim late payment interest, few companies seek to exercise the rights provided by this legislation, especially against larger companies, for fear of losing a customer or damaging the relationship AAT is in support of Government intervention on this issue and anything that addresses the imbalance is welcomed. ACAS promotes employment relations and makes impartial decisions on disputes. One potential Government intervention could be the setting up of a similar body to ACAS; to promote business relations and make impartial decisions on disputes between businesses. Furthermore, AAT believes that it would be helpful to set out a timeframe during which disputes should be resolved. Question 17 Do you agree that a business should report on whether they offer e-invoicing? Should this disclosure include any further information or simply be a tick box disclosure? AAT agrees that a business should report on whether they offer e-invoicing as a tick box disclosure. Question 18 Should businesses report on whether they offer supply chain finance? Should this disclosure also include the payment terms and average cost of this finance, or simply be a tick box disclosure? AAT recommends that businesses report on whether they offer supply chain finance, also known as reverse factoring, as it is a set of solutions that optimises cash flow by allowing businesses to lengthen their payment terms to their suppliers while providing the option for their large and SME suppliers to get paid early It is also recommended that the disclosure should include the payment terms and average cost of the finance. Question 19 Do you agree that a business should disclose whether it is a signatory of a Code and which code they belong to, if any? AAT agrees that a business should disclose whether it is a signatory of a Code and which code they belong to. For example, it would be useful to suppliers to know if the larger business is a signatory to the Prompt Payment code, which would demonstrate that the larger business embraces systems of good practice. Question 20 Do you have concerns about the practice of some suppliers having to pay to be included on supplier lists? If yes, why? AAT has concerns about the practice of some suppliers having to pay to be included on supplier lists. AAT considers that it introduces an unbalance into what should be, in our opinion an arms-length relationship, in favour of larger suppliers. 7

8 Question 21 Do you think that Government should take any action with respect to supplier lists, through this reporting requirement or otherwise? If so, what? AAT supports the view that legislation could be introduced to outline a tiered payment system, whereby smaller companies pay a lower fee for inclusion on a supplier list, compared to larger companies. Question 22 Do you agree that companies should report every three months covering at least the whole three month period? AAT agrees that companies should report every three months covering at least the whole three month period, as this is consistent with VAT reporting for a large proportion of companies. Question 23 Is a 30 day period enough time after the end of a quarter to provide a report of this nature? AAT recommends a 30 day period after the end of a quarter, to provide a report of this nature. As referenced at 3.42 (above), this is consistent with some VAT reporting. Question 24 Do you agree that companies reporting dates should be aligned with their financial reporting cycle? AAT agrees that companies reporting dates should be aligned with their financial reporting cycle. Question 25 Do you agree that this reporting requirement should not be included in a company s annual accounts but instead have to publish it on their website? If yes, do you think it would be useful for the information to also be released alongside the publication of a company s annual accounts? AAT agrees that this reporting requirement should be published on the company website AAT recommends that the information is released on a quarterly basis in line with a three monthly reporting requirement, in order that suppliers have access to up to date information It is also recommended that the information is published on the Companies House website, and legislation to be introduced stipulating that the publication is mandatory, in line with the publishing of an annual return and annual accounts. Question 26 Is The Gazette an appropriate online resource for companies without a website to use for reporting? If no, are there more suitable alternatives? As referenced at 3.47 (above), AAT is of the view that Companies House website should be more suitable vehicle for reporting. The basis for AAT making this suggestion is that Companies House website (now absorbed into GOV.UK) is already used by many agencies as a single reference point for information on companies, it provides its services on cost-covering basis and would be readily able to monitor and enforce compliance. 8

9 Question 27 Do you agree companies should be asked to report consistent with open data principles. If so, what should these be? AAT agrees that data is made available to the widest range of users for the widest range of purposes at no cost; available in a standard, structured format, so that it can be easily processed, has guaranteed availability and consistency over time so that others can rely on it, and that it is traceable Data made available in the way described at 3.49 (above) is likely to help a supplier make an informed decision on the payment practices of a customer-business against an industry norm, rather than having to create their own benchmarks for prompt payment comparison purposes (7.35, condoc). Question 28 How could we make this data as accessible and useful as possible? As referenced at 3.47 (above), AAT is of the view that the Companies house website should be used for reporting. This would make the data accessible as information may be viewed online or obtained over the telephone. Question 29 Do you agree that a company director should be responsible for signing off each report? AAT agrees that a nominated company director should be responsible for signing off each report as part of their fiduciary position. Question 30 Do you agree that breach of this requirement should be sanctionable by a criminal offence? AAT agrees that breach of this requirement should be sanctionable by a criminal offence, to be consistent with criminal offences for breaching the requirements for filing annual accounts at Companies House (see also 3.48, above) AAT is firmly of the opinion that appropriately enforced sanctions would encourage compliance and good practice. Question 31 Would you find guidance in complying with this reporting requirement helpful? If yes, who should produce this guidance? Guidance in complying with this reporting requirement would be helpful. AAT recommends for guidance to be produced by BIS and Companies House and hosted on Question 32 What comments do you have on our draft Regulations? AAT would welcome the sanctions to be in place across the UK in order to maintain a level playing field in the UK and avoid the situation of a company moving its registered office from England to Scotland or vice versa in order to avoid having to comply with the sanctions. 9

10 4. Conclusion 4.1. AAT endorses the proposal that companies report on a series of proposed reporting metrics (2.4, condoc) to give an indication of its payment performance: the proportion of invoices paid beyond terms; the proportion of invoices paid over 30, 60 and 120 days; and the average time taken to pay invoices. This will provide suppliers with data to compare different customers against a benchmark of payment performance AAT has the view that providing additional information in the reports, in narrative form, should be an option, to explain any variances as previously suggested in 3.30 (above). Further provision of narrative information is supported by AAT, to include: a description of standard payment terms; a company s invoice dispute resolution process; e-invoicing and membership of voluntary payment codes AAT recommends that the reporting requirements should be extended to include medium sized companies (3.10, 3.12 above) AAT recognises that large sole traders and partnerships may not be caught by the reporting requirements e.g. The John Lewis Partnership, or mutual organisations. It is recommended that a system is put in place to address this (3.11, above) It is recommended that the success of the reporting requirements are reviewed in three years, and consideration be given to expand the reporting requirements to include smaller companies (3.14, above) The proposal that the report requirements should include a description of the firm s standard payment terms is supported by AAT (3.16, above) AAT recommends that reporting of invoices paid beyond terms should include both percentage and value (7.20, condoc), to reduce the opportunity for information to be skewed. This should not incur a disproportionate amount of administrative time (3.25, above) In addition, a metric that includes both the proportion of invoices and the value of invoices paid in 30, 60, 120 and over 120 days, would provide a clearer picture of relevant information for suppliers when deciding whether to trade with someone (3.25, above) AAT supports the proposal that firms should be required to outline their dispute resolution processes, and furthermore, AAT recommends that the details are published on company websites as it is keen to reduce the number of firms that use disputes as a method of delaying payment (3.31, above) AAT suggests that the Government introduces some form of arbitration facility for businesses. For example, ACAS promotes employment relations and makes impartial decisions on disputes. A dedicated body, formed to promote business relations and make impartial decisions on disputes between businesses, could deter firms from using disputes to delay making payments (3.35, above) AAT is of the view that the reporting requirements should not be too onerous. Aligning the reporting dates with their financial reporting cycle, should minimise the administrative impact on firms, since the data required will be available within the information required for the preparation of other financial reporting requirements In line with the proposal for quarterly reports, AAT recommends that the information is published quarterly to ensure that suppliers have access to up to date information. AAT recognises that some larger firms can change their payment policies overnight, and suppliers need to be aware of these tactics, before engaging into contracts. Publication on the Companies House website would provide access for all suppliers, either online or by telephone. This is preferable to The Gazette which is less well known. 10

11 4.13. AAT concurs that the reporting requirements should fall within the scope of directors fiduciary duties, and a director should be responsible for signing off each report. This is thought to encourage compliance and accountability, and AAT fully agrees that breach of this requirement should be sanctionable by a criminal offence, similar to breaching the requirements for filing annual accounts at Companies House (3.53, above). 5. About AAT 5.1. AAT is a professional accountancy body with over 49,800 full and fellow members and 83,700 student and affiliate members worldwide. Of the full and fellow members, there are over 4,100 Members in Practice who provide accountancy and taxation services to individuals, not-for-profit organisations and the full range of business types (figures correct as at 31 December 2014) AAT is a registered charity whose objectives are to advance public education and promote the study of the practice, theory and techniques of accountancy and the prevention of crime and promotion of the sound administration of the law Thank you for the opportunity to respond to the consultation on Small business, enterprise & employment bill: Duty to report on payment practices and policies. 6. Further information If you have any questions or would like to discuss any of the points in more detail then please contact AAT at: and telephone: Aleem Islan Association of Accounting Technicians 140 Aldersgate Street London EC1A 4HY 11

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