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, confirming you can afford the repayments. Since early 2025 your accountant is right to refuse it, and the major banks have agreed to stop asking. The letter that was once a routine step in a self-employed application is now something the accounting bodies and the banks' own code of practice both discourage.
This matters most to self-employed and business-owner borrowers, whose income sits in tax returns and financial statements rather than on a payslip. For years the workaround was a letter from the accountant vouching for serviceability. That workaround is gone, and knowing what replaced it is the difference between a clean application and one that stalls on a request nobody will sign.
What actually changed
Two things moved in the same direction, and they reinforce each other.
The first is the 2025 Banking Code of Practice, which took effect on 28 February 2025. Clause 78 is explicit: a subscribing bank "will not ask a third party (such as your accountant) to certify that you can repay the Loan." Instead the bank assesses repayment capacity from what it can reasonably know about your financial position and account conduct. The certification step was removed from the banks' own rulebook.
The second is the position of the professional accounting bodies. CPA Australia, Chartered Accountants Australia and New Zealand (CA ANZ) and the Institute of Public Accountants (IPA) jointly maintain an Accountant's Letters Toolkit, first issued in May 2023 and updated in December 2024 to align with the new code. Their guidance to members is direct: requests for capacity-to-repay letters should be declined, because credit assessment is the lender's responsibility under its credit licence. The toolkit even provides members a template for declining the request.
So when your accountant won't sign, they aren't being difficult. They are following their professional body's explicit guidance, and the bank isn't supposed to be asking in the first place.
Why the letter carries risk for your accountant
Three reasons sit behind the refusal, and each one is legitimate.
Liability is the first. An accountant who certifies that you can repay a loan is giving an assurance about your future serviceability — an assessment they can't properly make and that exposes them to a negligence claim if the loan later fails. They see your income history, not the lender's serviceability model, your other commitments, or how rates move over a 30-year term.
Role is the second. Assessing whether a borrower can service a loan is the lender's job, carried out under the obligations attached to its Australian Credit Licence. An accountant substituting their judgment for that assessment is taking on a responsibility the law assigns to someone else.
Licensing is the third, and it's the one most people miss. For a consumer credit contract, a letter that assesses your capacity or the loan's suitability can stray into "credit activity" under the National Consumer Credit Protection Act. That activity requires an Australian Credit Licence, which most accountants don't hold. A well-meaning letter can put the accountant on the wrong side of the NCCP.
What your accountant can still confirm
The distinction that matters is between facts and opinions. Your accountant can state facts within their knowledge. They cannot offer 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 or service the repayments |
| That you are self-employed and your ABN or entity is trading | A guarantee or forecast of future income |
| Your GST registration status | That the loan is suitable or affordable for you |
| That specific figures match your lodged tax returns and financial statements | Any assurance the lender can rely on in place of its own assessment |
Restating a number that already appears on a lodged tax return is a factual statement, and many accountants will provide that where a lender genuinely needs it. Certifying that the number is enough to service a mortgage is an opinion on capacity, and that is the line the code and the toolkit draw. If a form asks your accountant to tick a box confirming you can meet the repayments, that form is out of date.
What lenders accept instead
Verification moved from the accountant's opinion to primary documents the lender assesses itself. For a self-employed borrower, that means one of three evidence paths.
Full-doc. The mainstream route. Two years of personal tax returns with the matching ATO Notices of Assessment, business financial statements for companies and trusts, ABN and GST history, and usually the last four quarters of BAS. The lender builds the income figure from these, including add-backs for depreciation and other non-cash items, then runs its own serviceability test. No accountant certification required.
One year of financials. All four major banks now accept a single year of financials for self-employed applicants, mostly capped at 80% LVR. The one-year policy detail decides which lender fits, but the common thread is the same: the bank verifies a lodged return and Notice of Assessment, not an accountant's letter.
Low-doc and alt-doc. Where two years of standard financials aren't available, the borrower declares their income and backs it with 6–12 months of BAS and 3–6 months of business bank statements. Where the accountant will engage, they confirm factual income figures rather than sign a capacity certificate. These products typically cap at 80% LVR and carry a rate premium of roughly 0.5%–1.5% p.a. above equivalent full-doc pricing. The scrutiny is real; it just doesn't run through a letter your accountant can't sign.
None of these paths asks your accountant to vouch for your ability to repay. That is the whole point of the shift.
If a lender still asks for one
Some smaller lenders and older low-doc forms haven't caught up. If you're handed a capacity-to-repay certificate to take to your accountant, treat it as a signal that the product or the process is behind the current code. A broker working current policy routes the file to a lender whose income verification stands on documents, not on an assurance the profession has spent years declining to give.
That routing is the practical value here. In most stalled files the income was always serviceable; the old letter was a formality that created liability for your accountant and delay for you. Match your structure, whether sole trader, company or trust, to a lender that reads self-employed income properly, and the letter drops out of the process entirely.
If you run a business and want a broker's read on which lenders verify your income without a letter your accountant can't sign, self-employed home loans is the starting point, and the application form takes about a minute.