Can my bookkeeper also audit my company?
No. The auditor must be a licensed CPA who is independent of the company: the Civil and Commercial Code bars directors, employees, agents and anyone with an interest in the company’s transactions from the role, and a CPA cannot meaningfully audit books their own office produced. In practice the audit is a second firm checking the first firm’s work, which is also why it is always a separate fee.
Last reviewed 12 October 2026
What the law actually says
Section 1208 of the Civil and Commercial Code allows an auditor to be a shareholder, but bars anyone with an interest in the company’s transactions beyond that, and states that no director, agent or employee of the company is eligible as auditor while in office. Sections 1209 and 1210 put the appointment where it belongs: the auditor is elected every year at the ordinary shareholders’ meeting, which also fixes the fee.
On top of that, the statements must be signed by a licensed auditor under the Accounting Act, and the licence carries professional ethics with an independence requirement. An auditor opining on bookkeeping their own office performed is auditing themselves, which is the thing the whole arrangement exists to prevent.
How it works in the Thai market
Most small companies buy bookkeeping from one firm, and that firm arranges an external CPA to do the year-end audit. That is normal and fine: the bookkeeper prepares, the auditor checks. What matters is that the person signing the audit report is not the person, or the office, that posted the entries.
It is also worth thirty seconds to check the auditor’s licence status before the report is signed. Statements signed under a lapsed licence are treated as not audited at all.
Why the separation is good for you
The audit is the one time a year someone outside your company, with their own licence at stake, looks at what your accountant did. Who is legally responsible if your accountant files something wrong is a sobering read: the company carries most of it. An independent audit is the main mechanism that catches problems while they are still one year deep.
It also means you can buy the two services separately, and often should. Bookkeeping is priced monthly on volume; the audit is priced on revenue, and three audit quotes are easy to compare precisely because the deliverable is identical: one signed opinion on the same set of statements.
Related questions
- How do I check that an auditor’s CPA licence is real?
- Who is legally responsible if my accountant files something wrong?
- Why is the audit fee sometimes higher than a whole year of bookkeeping?
Sources
- Civil and Commercial Code, sections 1208 to 1214 on auditors (English translation, Siam Legal library)
- Accounting Act B.E. 2543, section 11 (Thai, PDF)
This is general information about how a filing works, not accounting or tax advice for your company. Confirm anything that matters against the official notice or with your accountant. Spotted something out of date? Tell us and we will fix it.