We develop a simple model of convection in a fluid spherically accreti
ng on to a black hole. The model is based on a generalization of the s
tandard mixing length theory of convection and is applicable if the co
nvective velocities are either larger or smaller than the accretion ve
locity - as long as both are significantly lower than the speed of sou
nd. The change in the accretion velocity with radius leads to a radial
stretching of the inflowing fluid which impedes convection. Thus, in
order for convection to occur, the specific entropy has to grow inward
s at a rate higher than some threshold value [dS/dr < (dS/dr)(threshol
d) < 0], which modifies the familiar Schwarzschild criterion for conve
ction. However, this minimum rate is of such a small magnitude that ev
en, for instance, optically thick, gas-pressure-dominated accretion fl
ows, as discussed by Flammang, would necessarily involve convection in
their subsonic portions, although the convective luminosity would be
small compared with the total luminosity. We illustrate our model thro
ugh its application to accretion on to a small primordial black hole a
t the centre of a Sun-like star.