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What does UK GDPR mean for a small company's accounting data? Fee, record and the one trap

Short answer

Keeping your books is lawful without consent (it is a legal duty), and on its own it is exempt from the data protection fee; but the fee is due as soon as any of your processing is not exempt, and because bookkeeping runs every month, the under 250 staff exemption from keeping a record of processing does not help. Since 30 September 2026 the regulator is called the Information Commission (formerly the ICO). Tier 1 fee: GBP 52 a year, GBP 47 by direct debit (Data Protection (Charges and Information) Regulations 2018, reg. 3).

The four duties in one table

The fee exemption covers processing "for the purposes of keeping accounts, or records of purchases, sales or other transactions", deciding whether to accept a customer or supplier, and financial forecasts (Schedule para 2(2)(f)); data from a credit reference agency is excluded (para 2(4)). All read on legislation.gov.uk on 5 November 2026.

Worked case: Tom's shop pays, Mia does not

Tom runs a bike repair Ltd: 3 staff, turnover GBP 180,000, books in accounting software, payroll, a newsletter to his own customers, and one CCTV camera over the till.

One processing outside the list, so Tom pays. With 10 staff or fewer, or turnover up to GBP 632,000, he is tier 1: GBP 52, or GBP 47 by direct debit (reg. 3(1)(a), 3(2), 3(5)). Not paying can bring a fixed penalty of up to 150% of the top tier charge (Data Protection Act 2018, s.158).

Mia is a sole trader designer: no staff, no camera, books and invoices only, a mailing list of her own clients. Everything she does is on the exempt list, so she pays no fee. She still owes the other three duties.

Why a small company still needs a record of processing

Article 30(5) lifts the record duty for organisations under 250 people unless the processing is likely to risk people's rights, is not occasional, or includes special category data. Bookkeeping and payroll run every month, so on our reading of the text they are not occasional, and payroll often holds special category data (sick pay, trade union subscriptions). So write the record. For books it fits on half a page:

How Octobooks handles it

Octobooks is your processor under a DPA you accept at sign up, and your books are hosted in Germany (where accounting data may be stored). If you let Claude or another AI read your books, you choose what it sees: Standard, Careful (people as pseudonyms, contact and bank details left out) or Private (no personal data to the AI). How to set it: data protection and your AI. What else the DPA must say: do I need a data processing agreement? A general summary, not legal advice.

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Sources

Updated 2026-11-05. General information, not tax advice for your own case.