Guidance

Approved Contractor Scheme (ACS) sanctions framework

Updated 1 July 2026

The SIA is committed to HM Government’s principles of good regulation. We aim to be:

• proportionate
• accountable
• consistent
• transparent
• targeted

We use this framework to apply these principles to any breach of our ACS conditions. We list these conditions in our Get Approved booklet.

The framework gives example scenarios and then describes the actions we would take in response to each scenario. We can vary our approach from what we say here, but we will only do so in exceptional circumstances.

1. Explanation of terms

We use the following terms in this document:

• improvement need – an area where action is needed in order to meet the requirements of the ACS standard
• improvement notice – issued to a business or individual in relation to non-compliance with the Private Security Industry Act 2001
• restrict your use of licence dispensation – means that no new staff may be deployed under licence dispensation, although staff already working under licence dispensation may continue to do so
• withdraw your approval – this starts with a notice of intent to withdraw and is subject to appeal (initially to us and ultimately to the courts)
• further action – this may include warnings, improvement notices, formal investigation and prosecution (see our ‘Enforcement: what to expect from the SIA’ booklet for further details)
• special instruction – a temporary instruction to your assessing body, requiring them to focus on a specific area of your business where there is a perceived risk of non-conformance or non-compliance

2. Appeals

You can submit an appeal if you disagree with the decisions we make. We provide further details about appeals in our ‘Enforcement: what to expect from the SIA’ booklet.

3. Sanctions

3.1 Up to 3 improvement needs

Your assessor or another authorised person identifies up to 3 improvement needs during or outside the assessment process.

We will:

• require you to produce an action plan within 5 working days, setting out how you will address the improvement needs
• require you to successfully pass a follow-up assessment – with no improvement needs – within 6 weeks of your original assessment

We may:

• restrict or withdraw your use of licence dispensation if any improvement needs relate to this area
• withdraw your approval if all improvement needs are not met within the required timescale
• apply an additional condition of approval that requires you to undertake another assessment at your expense – this is in addition to the follow-up assessment mentioned above

You must address any offences under the Private Security Industry Act 2001 immediately. We may take further action if you do not.

3.2 4 to 6 improvement needs

Your assessor or another authorised person identifies 4 to 6 improvement needs during or outside the assessment process.

We will:

• require you to produce an action plan within 5 working days, setting out how you will address the improvement needs
• require you to successfully pass a follow-up assessment – with no improvement needs – within 6 weeks of your original assessment

We may:

• restrict your use of licence dispensation
• withdraw the use of licence dispensation if any improvement needs relate to this area or to offences under the Private Security Industry Act 2001
• withdraw your approval if all improvement needs are not met within the required timescale
• apply an additional condition of approval that requires you to undertake another assessment at your expense – this is in addition to the follow-up assessment mentioned above

You must address any offences under the Private Security Industry Act 2001 immediately. We may take further action if you do not.

3.3 More than 6 improvement needs

Your assessor or another authorised person identifies more than 6 improvement needs during or outside the assessment process.

We will:

• require you to produce an action plan within 5 working days, setting out how you will address the improvement needs
• Withdraw your approval, but on a case-by-case basis we retain the option to allow a follow-up assessment, which you must pass with no improvement needs

We may:

• restrict your use of licence dispensation while we go through the process of withdrawing your approval
• withdraw the use of licence dispensation if any improvement needs relate to this area or to offences under the Private Security Industry Act 2001
• apply an additional condition of approval that requires you to undertake another assessment at your expense – this is in addition to the follow-up assessment mentioned above

If you use our Licence Management service, we may also impose sanctions from our Licence Management sanctions framework.

You must address any offences under the Private Security Industry Act 2001 immediately. We may take further action if you do not.

3.4 The business or its controlling minds are no longer ‘fit and proper’

Your business or its directors are under criminal investigation, are linked to serious and organised crime, or we have suspended or revoked the director’s licences.

We will decide what action to take on a case-by-case basis.

We may withdraw your approval if both of the following apply:

• there is a risk to public or employee safety
• there is sufficient disclosable evidence of the risk

We may also take further action.

3.5 No valid ACS assessment

You have not undertaken an ACS assessment within the required period, or you have not paid your assessing body the fees they are due.

Unless the delay has been agreed by us and your ACS assessing body, we will:

• restrict your use of licence dispensation
• withdraw your approval

3.6 Annual return not submitted

You have not submitted your annual return to us.

We may withdraw your approval

3.7 Malpractice or non-compliance with ACS conditions

You are guilty of malpractice, or you are in breach of ACS conditions.

We will decide what action to take on a case-by-case basis.

We may:

• issue you with a special instruction prior to your next ACS assessment
• conduct an inspection of your business
• require you to undertake an additional ACS assessment at your expense
• apply an additional condition to your approval
• restrict or withdraw your use of licence dispensation
• withdraw your approval

3.8 Improvement notice issued

We issue you with an improvement notice (see Get Approved).

We may:

• restrict your use of licence dispensation until we lift the improvement notice
• withdraw your approval if the improvement notice is not satisfied

If the improvement notice raises conformance issues, then we may bring forward the date of your next ACS assessment.

If the improvement notice covers activities for which you are not approved, then we will refuse or place on hold any application for the additional activity to be approved until you have been compliant with the improvement notice for a period of 6 months.

3.9 Bringing our Approved Contractor Scheme into disrepute

Your activities bring the ACS into serious disrepute (for example, your directors or officers do not uphold proper standards of conduct or competence, which puts the safety of the public at risk).

We may withdraw your approval if both of the following apply:

• there is a risk to public or employee safety
• there is sufficient disclosable evidence of the risk

3.10 1 or more improvement needs for non-conformance with HMRC requirements

Your assessor identifies 1 or more improvement needs during your ACS assessment that relate to any of the following:

• the use of personal service companies for regulated activity
• self-assessment workbook indicator 4.2.1 (“the organisation complies with all the relevant tax and national insurance legislation concerning people they deploy… this requires complying with all of the HMRC guidance”)
• self-assessment workbook indicator 6.1.2 (specifically, “follows HMRC guidance for due diligence record keeping for the use of labour providers”), where there is no evidence of conformance to 4.2.1
• you no longer meet our eligibility requirements

We will withdraw your approval. If you appeal, we may, at our discretion, require you to successfully pass a follow-up assessment with no improvement needs. We will set a deadline for this.

If we withdraw your approval, we will then report your company to HMRC for them to take further action if they wish.

We may apply an additional condition of approval that requires you to undertake another assessment at your expense.

[ACS/26-27/002]