Changing accountants should improve a business’s financial reporting, tax compliance and access to management information. However, an inadequately planned transition can instead create missing records, duplicated filings, unclear responsibilities and avoidable exposure to penalties.
In Portugal, the process is also governed by professional rules applicable to the contabilista certificado, or certified accountant. A new accountant cannot simply take over the accounting file without first completing the required professional communications with the outgoing accountant.
This guide explains how to switch accountants in Portugal while preserving accounting continuity, complying with the rules of the Ordem dos Contabilistas Certificados (OCC, i.e. the Portuguese Accountants’ Guild), and ensuring that no tax, payroll or reporting obligation falls between two service providers.
How do you switch accountants in Portugal?
To switch accountants in Portugal, the business should:
- Review and terminate the existing written engagement correctly.
- Agree on an effective handover date.
- Settle any liquid and due professional fees.
- Allow the incoming certified accountant to contact the outgoing accountant in writing.
- Allocate responsibility for outstanding tax returns and year-end work.
- Sign a new written accounting-services agreement.
- Transfer the complete accounting, tax and payroll records.
- Sign a detailed handover or receipt report.
- Update professional responsibility records and electronic authorisations.
- Reconcile the opening balances and compliance calendar immediately after the transfer.
The process should be coordinated before the new accountant formally assumes responsibility.
Why changing accountants in Portugal is not merely an administrative decision
Portuguese companies with organised accounting must have their accounting records and relevant tax filings placed under the responsibility of a certified accountant.
The relationship is therefore not limited to a commercial services agreement. Certified accountants are subject to statutory and deontological duties relating to professional independence, technical responsibility, confidentiality, cooperation and loyalty between colleagues.
Under Article 74 of the Statute of the OCC, an incoming accountant must contact the outgoing accountant in writing before assuming responsibility. The incoming professional must also verify whether the fees, expenses and salaries connected with the accounting services have been paid. Where the incoming accountant becomes aware of debts to the previous accountant or repeated legal non-compliance by the client, the accountant should not assume responsibility for the accounting.
The OCC Code of Ethics reinforces this procedure. The outgoing accountant must normally respond within 15 days, confirming whether the relevant amounts have been paid and communicating any circumstances that may influence the incoming accountant’s decision to accept the engagement. If contacting the outgoing accountant proves impossible, the incoming accountant should inform the OCC.
For this reason, a business cannot ask its new accountant to “take over immediately” while leaving the contractual termination, unpaid invoices and handover documentation unresolved.
The clean handover checklist
1. Review the current accounting-services agreement
Start with the written engagement entered into with the current accountant or accounting firm.
The contract should identify its duration, effective date, scope of services, document-delivery procedures, professional fees and payment terms. Portuguese professional rules require accounting-services agreements to be made in writing. The OCC Code of Ethics also provides that, for independent accounting services, the agreement should generally cover at least one financial year, unless it is terminated for just cause or by mutual agreement.
Check specifically:
- The notice period;
- The accepted methods of giving notice;
- The proposed termination date;
- Any provisions concerning year-end closing;
- Additional charges for handover or closing work;
- Outstanding fees and expenses;
- The ownership and return of physical and digital records.
The client should not assume that an informal email automatically produces an immediate and legally effective termination.
2. Establish a precise cut-off date
The outgoing and incoming accountants should work from a clearly documented effective date.
Vague arrangements such as “the new accountant will start next month” create uncertainty over who is responsible for VAT returns, payroll processing, withholding-tax declarations, annual accounts and corporate income tax filings.
A proper handover memorandum should state, for example:
The outgoing accountant remains responsible for transactions and obligations relating to periods ending on or before 30 September. The incoming accountant assumes responsibility for accounting periods beginning on 1 October, subject to completion of the professional handover and confirmation of the opening balances.
The cut-off date should be aligned with the company’s VAT periodicity, payroll cycle, financial year and any imminent statutory deadlines.
Where possible, make the change at the end of a month or quarter. A mid-period transfer can be completed, but it requires more detailed reconciliation.
3. Deal with outstanding professional fees before the takeover
The payment status of the outgoing accountant is not a private matter that can simply be ignored by the incoming professional.
Before accepting the engagement, the new certified accountant must contact the previous accountant in writing and ascertain whether fees, expenses or relevant salaries remain unpaid. Failure to comply with this professional duty can expose the incoming accountant or accounting firm to liability for liquid and due amounts owed to the predecessor.
Accordingly, the client should request:
- A final statement of account;
- Identification of any disputed and undisputed amounts;
- Copies of unpaid invoices;
- Confirmation of payment once settled;
- Written clarification of any genuine fee dispute.
An unresolved disagreement should not be disguised as a completed handover. Where an amount is genuinely disputed, the parties should document the nature of the dispute and obtain appropriate advice rather than expecting the incoming accountant to disregard it.
4. Allow the accountants to complete the OCC loyalty procedure
The professional communication should take place directly between the incoming and outgoing certified accountants.
This contact should be in writing and should ordinarily cover:
- Confirmation that the outgoing accountant was responsible for the accounting;
- The intended effective date of the change;
- The existence or absence of outstanding fees;
- The status of the accounting records;
- Missing information or unresolved compliance issues;
- Pending tax inspections, notifications or corrections;
- The allocation of year-end and outstanding filing responsibilities.
The outgoing accountant has a duty to cooperate with the successor by providing the relevant elements and explanations requested. The OCC rules treat this cooperation as a reciprocal professional duty, not as an optional courtesy.
The client should authorise the exchange of information where necessary and avoid obstructing direct communication between the two professionals.
5. Decide who completes the outstanding returns and year-end accounts
One of the most frequent handover failures is the absence of a written responsibility matrix.
The parties must identify who will complete each outstanding obligation, including:
- Periodic VAT returns;
- Recapitulative statements;
- Withholding-tax declarations;
- Monthly payroll and Social Security reporting;
- Annual wage and tax statements;
- Annual corporate income tax return;
- Informação Empresarial Simplificada;
- Financial statements and shareholder approval documentation;
- Corrections to previous accounting periods;
- Responses to pending tax notices.
Particular care is required when the change occurs close to the end of the financial year. Under the OCC Statute, a certified accountant may not, without a justified reason recognised by the OCC, refuse to sign the relevant tax returns, financial statements and annexes when fewer than three months remain before the end of the financial year concerned.
OCC guidance also indicates that, in certain termination scenarios occurring during the final three months of the financial year, the outgoing accountant may remain responsible for completing the year-end work unless a written agreement expressly transfers that obligation to the incoming accountant.
The responsibility matrix should therefore be signed or expressly accepted by the company and both service providers.
6. Execute the new written engagement before services begin
The incoming accountant should not operate under an informal or undefined arrangement.
The new agreement should clearly specify:
- The services included in the monthly fee;
- The services charged separately;
- The start date;
- Document-delivery deadlines;
- Payroll responsibilities;
- Tax-compliance responsibilities;
- Responsibility for accounts prepared by the predecessor;
- The treatment of historical corrections;
- Client approval procedures;
- Communication channels;
- Termination provisions;
- Data-protection and confidentiality arrangements.
The OCC Code of Ethics requires written contracts and provides for their communication to the OCC within the applicable period and before the commencement of reserved professional functions.
The incoming accountant should also complete the appropriate registration of professional responsibility. Under the OCC Statute, certified accountants communicate the entities for which they are responsible to the OCC, which transmits that information to the Portuguese Tax and Customs Authority and other relevant public bodies.
7. Transfer the complete accounting file
A clean accounting handover is much broader than the delivery of a trial balance.
The handover package should ordinarily include:
Core accounting records
- Chart of accounts;
- General ledger;
- Trial balances, including detailed third-party balances;
- Opening and closing journals;
- Bank reconciliations;
- Customer and supplier account statements;
- Accruals and deferrals;
- Loan and shareholder-account reconciliations;
- Fixed-asset register and depreciation schedules;
- Inventory records;
- Foreign-exchange calculations;
- Provisions and impairment calculations.
Tax records
- Submitted tax returns and filing receipts;
- VAT ledgers and reconciliations;
- Withholding-tax records;
- Corporate income tax calculations;
- Tax-loss schedules;
- Deferred-tax calculations, where applicable;
- Tax assessments, notices and correspondence;
- Payment plans and outstanding tax debts;
- Information on pending inspections, objections or corrections.
Payroll records
- Employee master data;
- Employment contracts and amendments;
- Monthly payroll reports;
- Holiday and Christmas allowance records;
- Expense and benefit policies;
- Social Security declarations;
- Wage-tax submissions;
- Records of absences, holidays and overtime;
- Outstanding employee or management reimbursements.
Digital accounting data
- Accounting SAF-T file;
- Database backups;
- Export files from the accounting software;
- Supporting-document archive;
- Audit trail and journal listings;
- Document-management indexes;
- Relevant electronic certificates and licences.
The OCC considers that accounting information subject to statutory archiving should be delivered in physical or digital form, including the accounting SAF-T and backups of the underlying accounting database where applicable.
8. Distinguish client-owned documents from the accountant’s work product
Outstanding fees do not give the outgoing accountant an unrestricted right to retain everything.
Documents originally supplied by the client, such as invoices, contracts and other supporting records, remain the client’s property and should be returned. OCC guidance distinguishes these from documents resulting from the accountant’s own professional work, such as ledgers, trial balances, financial statements and tax returns.
Where professional fees are liquid, due and unpaid, the OCC’s practical guidance indicates that work product relating to the unpaid period may, in certain circumstances, be retained. Client-owned source documents must nevertheless be returned.
This distinction is important. Neither the client nor the outgoing accountant should describe the entire accounting archive as a single indivisible file.
The safest approach is to identify separately:
- Original client documentation;
- Legally required accounting archives;
- Professional work product;
- Software backups and export files;
- Records temporarily retained to complete an agreed outstanding filing.
9. Sign a detailed handover report
The OCC Code of Ethics allows a maximum period of 60 days following termination for the delivery of books and documents held by the outgoing accountant. A signed receipt or handover report must identify the records transferred.
The 60-day period is a maximum, not a recommended operational target. Where payroll, VAT or other deadlines are approaching, waiting until the end of that period may create material compliance risk.
The handover report should specify:
- The date and method of delivery;
- Each accounting period covered;
- The physical files transferred;
- The digital files transferred;
- The accounting-software format;
- The date of the latest processed transaction;
- The most recent bank reconciliation;
- Outstanding filings;
- Missing documentation;
- Records retained temporarily and the reason;
- The identity and signature of the recipient.
Descriptions such as “2019–2025 documents” are insufficient. The inventory should identify the actual books, files, folders, backups and reports delivered.
The OCC provides model forms for receiving and delivering accounting documentation, which can be adapted to the circumstances of the company.
10. Complete a post-handover diagnostic review
The incoming accountant should not treat the predecessor’s closing trial balance as automatically complete or correct.
Before processing the first reporting period, the new accountant should verify:
- Whether opening balances agree with the latest approved accounts;
- Whether tax returns reconcile with the ledger;
- Whether bank accounts have been reconciled;
- Whether customer and supplier balances are substantiated;
- Whether payroll liabilities agree with submitted declarations;
- Whether fixed assets and depreciation are complete;
- Whether shareholders’ loans and current accounts are properly classified;
- Whether VAT carried forward agrees with the Tax Authority’s records;
- Whether tax debts or notices remain outstanding;
- Whether all legally required electronic files are available.
Historical problems should be documented in an onboarding report. Any corrective work should be scoped and priced separately from ordinary monthly accounting.
Can an accountant refuse to release the company’s records?
An accountant cannot normally retain client-owned source documents merely because fees remain unpaid. Invoices, contracts and other documents delivered by the client remain the client’s property.
However, OCC guidance recognises a distinction between those records and work produced by the accountant. Where fees are liquid, due and unpaid, certain accounting work product relating to the unpaid period may be retained. At the same time, the incoming accountant is subject to professional restrictions on accepting the engagement while qualifying debts to the outgoing accountant remain outstanding.
Disputes should therefore be addressed before the intended takeover date.
How long does it take to change accountants in Portugal?
A straightforward transfer may be organised within a few weeks, provided that:
- The existing agreement is terminated correctly;
- Fees are settled;
- The outgoing accountant responds promptly;
- The accounting records are up to date;
- No major discrepancies are identified.
Two OCC time limits are particularly relevant:
- The outgoing accountant should normally respond to the incoming accountant’s professional communication within 15 days.
- Books and documents held by the outgoing accountant must be delivered within a maximum of 60 days following termination, accompanied by a detailed signed receipt or handover report.
The contractual notice period may nevertheless be longer, and year-end responsibilities may continue beyond the operational transfer date.
When is the best time to change accountants?
The technically easiest time is usually after completion of a month, VAT period or financial year.
Nevertheless, a company should not postpone a necessary change where there are persistent communication failures, missed deadlines, inadequate reporting or unresolved compliance concerns.
The relevant question is not simply whether the company is changing mid-year. It is whether the parties can establish a reliable cut-off date, reconcile the records and allocate every outstanding obligation in writing.
Common mistakes when changing accountants
The most serious handover problems usually arise when a company:
- Appoints the new accountant before completing the OCC professional procedure;
- Ignores outstanding fees owed to the predecessor;
- Fails to review the termination clauses in the existing agreement;
- Assumes the previous accountant will automatically close the financial year;
- Transfers only PDF reports and not the underlying accounting database;
- Fails to obtain the accounting SAF-T and database backups;
- Shares personal portal passwords instead of establishing proper authorisations;
- Accepts undocumented opening balances;
- Does not obtain a signed inventory of the records transferred;
- Leaves tax notices and historical corrections outside the handover scope.
A rushed transition can leave the new accountant technically responsible for records that have not yet been received, tested or reconciled.
Switching to an accountant in Madeira
A company established elsewhere in Portugal may generally engage an accounting provider based in Madeira, provided that the accountant or accounting firm is appropriately registered and can support the company’s operational requirements.
For businesses operating through the Madeira International Business Centre, the handover should also address the company’s licensing conditions, eligible activities, employment requirements, investment records and applicable reduced corporate income tax framework. These matters require specific monitoring and should not be treated as ordinary bookkeeping entries.
A Madeira company should therefore select an accounting provider familiar with both general Portuguese tax compliance and the company’s regional or MIBC-specific obligations.
How MCS approaches accounting handovers
Madeira Corporate Services approaches a change of accountant as a controlled compliance project rather than a simple transfer of files.
Before assuming responsibility, the relevant team must complete the required onboarding and professional procedures, including:
- Client acceptance and KYC;
- Review of the proposed accounting scope;
- Written contact with the outgoing certified accountant;
- Verification of outstanding fees;
- Execution of a written services agreement;
- Receipt and inventory of the accounting records;
- Review of outstanding tax and payroll obligations;
- Reconciliation of the opening accounting position.
Where historical accounting is incomplete, inconsistent or unreconciled, corrective work is assessed separately before MCS confirms that the records can be relied upon.
Frequently asked questions
Can I change accountants at any time in Portugal?
The practical ability to change depends on the written accounting-services agreement, its notice provisions and the circumstances of termination. OCC rules state that an independent-services contract should generally have a minimum duration of one financial year, except in cases of just cause or mutual agreement.
Does my new accountant need to speak to my old accountant?
Yes. Before accepting responsibility, the incoming certified accountant must contact the outgoing accountant in writing and verify the position regarding professional fees, expenses and other relevant matters.
How long does the former accountant have to answer?
Under the OCC Code of Ethics, the outgoing accountant should inform the successor within a maximum of 15 days whether the relevant amounts have been paid and disclose circumstances that may affect acceptance of the engagement.
Must the outgoing accountant provide the accounting SAF-T?
Where the relevant accounting records are to be returned and there is no valid basis for retention, OCC guidance includes the accounting SAF-T and backups of the supporting accounting database among the digital records that should be delivered.
Can the old accountant keep my invoices because I owe fees?
Client-owned documents, including invoices and contracts supplied to the accountant, should be returned. The possible right of retention identified by OCC guidance concerns professional work product associated with liquid, due and unpaid fees, not the client’s original supporting documents.
Who is responsible for the annual accounts after a mid-year change?
The parties must agree this in writing. Depending on the timing, the applicable professional rules and the terms of termination, the outgoing accountant may remain responsible for certain year-end obligations unless responsibility is expressly transferred to the successor.
Final considerations
Switching accountants in Portugal is entirely manageable when it is treated as a structured professional transition.
The essential elements are a valid contractual termination, settlement of qualifying outstanding fees, written communication between the certified accountants, a precise allocation of compliance responsibilities, complete transfer of the accounting data and a signed handover report.
The new accountant should only assume responsibility once the records, professional communications and contractual arrangements are sufficiently clear. A clean handover protects the company, the outgoing accountant and the incoming accountant, and significantly reduces the risk of missed filings, unreliable balances and disputes over responsibility.
This article is provided for general informational purposes only and reflects a high-level interpretation of the Portuguese legal, regulatory and professional framework applicable to the replacement of certified accountants as at the date of publication. It is not intended to constitute, and should not be relied upon as, legal, tax, accounting, employment, contractual or other professional advice.
The applicable procedure may vary depending on the terms of the accounting-services agreement, the timing of the termination, the existence of outstanding professional fees, the status of the accounting records, pending tax or reporting obligations, and the specific circumstances of the company and the certified accountants involved.
References to the Statute and Code of Ethics of the Ordem dos Contabilistas Certificados, OCC guidance, tax procedures or professional duties should be verified against the legislation, regulations and official guidance in force at the relevant time, as these may be amended, supplemented or interpreted differently by the competent authorities or professional bodies.
Nothing in this article creates a professional, advisory, fiduciary or contractual relationship between the reader and Madeira Corporate Services, nor should it be understood as confirmation that Madeira Corporate Services will accept a particular engagement or assume responsibility for accounting records prepared by another service provider. Any potential engagement remains subject to prior client acceptance, KYC and AML procedures, professional conflict checks, review of the accounting records, completion of the applicable OCC handover procedures, execution of a written services agreement and confirmation of the agreed scope of work.
Businesses considering a change of accountant should obtain advice from a Portuguese certified accountant and, where contractual or legal issues arise, from a suitably qualified Portuguese lawyer before taking action.
Miguel Pinto-Correia holds a Master Degree in International Economics and European Studies from ISEG – Lisbon School of Economics & Management and a Bachelor Degree in Economics from Nova School of Business and Economics. He is a permanent member of the Order of the Economists (Ordem dos Economistas)… Read more
