Reko consultants gain right to report suspected crime

FAR has amended Reko, Svensk standard för redovisnings- och lönetjänsterFAR, so that authorised accounting and payroll consultants gain the right to report suspected crime to Ekobrottsmyndigheten (the Economic Crime Authority)FAR. The change creates a new exception to the consultant's duty of confidentialityFAR, covering suspected bokföringsbrott (accounting offences), skattebrott (tax offences) and försvårande av skattekontroll (obstructing tax control)FAR that the consultant learns of in connection with an engagementFAR.

The starting point is unchanged: the consultant must first try to get the client to correct the matterFAR. The new reporting right does not make the consultant an investigatorFAR and does not mean going straight to the authoritiesFAR. Under Reko 110 (the consultant's role and task) the consultant reacts and acts first; if the client does not correct, reporting follows as before under Reko 850 on reporting at material eventsFAR. As authorised consultant Camilla Carlsson puts it, rectification always comes first — the reporting right is a tool for situations where that is not enough.

The amendment covers both accounting and payroll engagementsFAR. For an accounting consultant it could concern business transactions omitted from the books, manipulated accounting records, or deliberately false statements in tax returns. For a payroll consultant it could involve suspected undeclared cash wages, incorrect employer declarations, or compensation deliberately withheld from taxation. It is not the consultant's task to establish whether an offence was actually committed, Carlsson stresses.

Payroll consultants get explicit attention: through their engagements they often see data suggesting something is wrong. Authorised payroll consultant Emelie Hansson notes the profession should watch for unusual deviations and act when warranted. Examples of risk indicators include discrepancies between payslips, employment contracts, time reports, schedules, bank payments and employer declarations; unusually many corrections of individual data or recurring retroactive salary payments; and records withheld despite repeated reminders or figures changed when an authority inspection looms.

The threshold is low: the consultant needs no proofFAR and must conduct no investigation of their ownFAR. It suffices that circumstances give reason to suspect an offenceFAR; investigation and assessment rest with the competent authoritiesFAR.

FAR links the decision to its eight proposals against economic crime, one of which is updating reporting duties — including examining how accounting and payroll consultants can be brought under requirements to act and report when they see reason to suspect crime. The change is also framed as a step towards a future state-authorisation regime for accounting consultants, easing adaptation to any future reporting obligations. Consequential amendments accompany the change: clarifications of the confidentiality rules and their exceptions, plus follow-on changes to Reko 130, 725 and 850 making clear the consultant may report the listed offences and need not investigate them.

Legal basis: FAR's amendments to Reko (Svensk standard för redovisnings- och lönetjänster) — new confidentiality exception for suspected bokföringsbrott, skattebrott and försvårande av skattekontroll, with consequential changes to Reko 130, 725 and 850.