Your accountant is right to say no
An accountant's letter for a home loan, often called a capacity-to-repay certificate or an accountant's declaration, is a document a lender asks your accountant to sign, saying you can afford the repayments. Since early 2025 your accountant is right to refuse it, and the major banks have agreed to stop asking. It used to be a routine step in a self-employed application. Now both the accounting bodies and the banks' own code of practice discourage it.
This matters most if you're self-employed or own a business, because your income shows up in tax returns and financial statements, not on a payslip. For years the workaround was a letter from your accountant saying you could afford the loan. That workaround is gone. If you know what replaced it, your application goes through cleanly. If you don't, it can stall on a request nobody will sign.
What changed
Two changes happened at once, and they back each other up.
The first is the 2025 Banking Code of Practice, which took effect on 28 February 2025. Clause 78 says plainly that a bank that signs up to the code "will not ask a third party (such as your accountant) to certify that you can repay the Loan." The bank works out whether you can repay from what it can reasonably know about your finances and how you run your accounts. The certification step is gone from the banks' own rulebook.
The second is the position of the accounting bodies. CPA Australia, Chartered Accountants Australia and New Zealand (CA ANZ) and the Institute of Public Accountants (IPA) jointly publish an Accountant's Letters Toolkit. It first came out in May 2023 and was updated in December 2024 to match the new code. Their advice to members is clear: decline requests for capacity-to-repay letters, because assessing credit is the lender's job under its credit licence. The toolkit even gives members a template for saying no.
So when your accountant won't sign, they aren't being difficult. They're following their professional body's guidance, and the bank shouldn't be asking anyway.
Why the letter is risky for your accountant
There are three reasons behind the refusal, and each one is fair.
The first is liability. An accountant who signs off that you can repay a loan is vouching for your future ability to pay. They can't properly judge that, and they could be sued for negligence if the loan goes bad. They see your income history. They don't see the lender's serviceability model, your other debts, or how rates will move over a 30-year loan.
The second is whose job it is. Deciding whether a borrower can repay a loan is the lender's job, done under the rules that come with its Australian Credit Licence. An accountant who makes that call is taking on a responsibility the law gives to someone else.
The third is licensing, and it's the one most people miss. For a consumer credit contract, a letter that judges whether you can repay, or whether the loan suits you, can count as "credit activity" under the National Consumer Credit Protection Act. That needs an Australian Credit Licence, and most accountants don't have one. A well-meant letter can put your accountant in breach of the NCCP.
What your accountant can still confirm
The line is between facts and opinions. Your accountant can state facts they know. They can't give an opinion on whether you can repay.
| Your accountant can confirm | Your accountant cannot confirm |
|---|---|
| That they are your accountant and prepare your financials | That you can afford the repayments |
| That you are self-employed and your ABN or business is trading | A guarantee or forecast of future income |
| Whether you're registered for GST | That the loan suits you or is affordable for you |
| That specific figures match your lodged tax returns and financial statements | Anything the lender can rely on instead of doing its own assessment |
Repeating a number that's already on a lodged tax return is a statement of fact, and many accountants will do that when a lender really needs it. Saying that number is enough to cover a mortgage is an opinion on whether you can repay, and that's the line the code and the toolkit draw. If a form asks your accountant to tick a box saying you can meet the repayments, the form is out of date.
What lenders accept instead
Lenders now check your income from the original documents themselves, instead of relying on your accountant's opinion. If you're self-employed, that means one of three types of evidence.
Full-doc is the usual route. You provide two years of personal tax returns with the matching ATO Notices of Assessment, business financial statements for companies and trusts, your ABN and GST history, and usually the last four quarters of BAS. The lender works out your income from these, including add-backs for depreciation and other non-cash items, then runs its own test of whether you can repay. Your accountant doesn't need to certify anything.
One year of financials is the second option. All four major banks now accept a single year of financials from self-employed applicants, mostly up to 80% LVR. The one-year policy detail decides which lender suits you, but they all work the same way: the bank checks a lodged return and Notice of Assessment, not an accountant's letter.
Low-doc and alt-doc loans are the third. If you don't have two years of standard financials, you declare your income and back it up with 6 to 12 months of BAS and 3 to 6 months of business bank statements. If your accountant is involved, they confirm the income figures as facts instead of signing a capacity certificate. These loans usually go up to 80% LVR and cost roughly 0.5% to 1.5% p.a. more than similar full-doc loans. The lender still checks properly. It just doesn't rely on a letter your accountant can't sign.
None of these options asks your accountant to vouch for your ability to repay. That's the whole point of the change.
If a lender still asks for one
Some smaller lenders and older low-doc forms haven't caught up. If you're given a capacity-to-repay certificate to take to your accountant, take it as a sign that the loan or the lender's process is behind the current code. A broker who knows current policy will send your application to a lender that checks your income from documents, not from a promise accountants have refused to give for years.
That's where a broker earns their keep. In most stalled applications, the borrower could always afford the loan. The old letter was a formality that put your accountant at risk and slowed you down. Match your structure (sole trader, company or trust) to a lender that reads self-employed income properly, and the letter drops out of the process completely.
If you run a business and want a broker's view on which lenders will check your income without a letter your accountant can't sign, start with self-employed home loans. The application form takes about a minute.