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Working template

New bookkeeping client checklist

Document steps before accepting and during a bookkeeping engagement.

For: External bookkeeping practices

Ticking a box does not perform the measure.

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Before use

Check current sector rules in the related articles. Add accountable roles, specific sources and steps actually performed. Do not enter unnecessary personal data.

How to complete the template

  1. Activity, relationship or occasional transaction, trigger date

    Is the engagement occasional or expected to recur? Record its subject and start date; the fee alone is not a reliable transaction-value test.

  2. Client, representative and authority; identification actually performed

    Who contracts and gives binding instructions? Verify identity and authority. For remote identification, retain all steps of the chosen statutory method.

  3. Purpose, beneficial owner, PEP, sanctions and risk factors

    How does the client earn money, who owns it and what does it expect? Compare explanations with evidence; resolve inconsistent activities and payments.

  4. Uncertainties, measures, accountable role and approval

    Can the client be accepted, is more evidence needed, or does section 15 apply? Assess reporting under section 18 separately; refusal does not replace reporting.

  5. Sources, versions, date and update triggers; own archive

    What triggers review: a new owner, payer, service or country? Assign responsibility and evidence location, not just a checklist completion date.

Illustrative use

MODEL ACC-01: monthly bookkeeping for a Czech company; business relationship, identify director before acceptance. Action: evidence direct ownership and activity. Status: open, service not yet started.

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When the case is uncertain

Missing identification or an explanation of funds? Keep the item open, specify evidence needed and assess section 15 and possible suspicion.

Legal basis: § 2, § 7–9a, § 15–16, § 18

V01-2026-10-04 · Redakce eAML.cz

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