Decision-support · Schedule 1 Item 2
Is your accounting practice a Trust and Company Service Provider?
This assessment asks factual questions about the services your practice actually performs for clients. It then applies rule-based gateway logic — not a percentage score — to reach one of three outcomes: accountable institution, not indicated on the answers provided, or legal and compliance review required.
How the tool works
- An eleven-step questionnaire with binary Yes/No answers, conditional follow-up questions, explanations and evidence capture.
- Four gateways tested separately, each shown as Triggered, Potentially triggered or Not triggered on current facts.
- Answers autosave in this browser only, and can be downloaded as a PDF report. No client personal information is requested.
Guidance version 1.0 · reviewed 2026-08-15
Purpose of PCC 6A
Why this guidance note exists
Public Compliance Communication 6A is issued by the Financial Intelligence Centre to explain when a person or firm providing trust and company services falls within Item 2 of Schedule 1 to the FIC Act, and therefore becomes an accountable institution. It clarifies which activities — company formation, acting as or arranging a director, nominee shareholder or trustee, providing a registered office or business address, and administering trusts or client assets — bring a practice inside Item 2, and which routine accounting, audit and tax services do not.
The purpose of this tool is to apply that guidance consistently to your practice: it tests the actual services you perform against each Item 2 gateway and records a dated, referenced determination you can keep as evidence of the conclusion reached.
Gateway A
Company-service gateway
Preparing for or carrying out transactions for a client where the client is assisted in planning or execution of: the organisation of contributions necessary for the creation, operation or management of a company, external company or foreign company; the creation, operation or management of such a company; or the operation or management of a close corporation.
Gateway B
Nominee gateway
Carrying on the business of acting for a client as a nominee, or arranging for another person to act as a nominee for a client.
Gateway C
Trust-creation gateway
Carrying on the business of creating a trust arrangement for a client.
Gateway D
Trust-property gateway
Carrying on the business of preparing for or carrying out transactions, including acting as trustee, relating to the investment, safekeeping, control or administration of trust property.