Corporate report

Annual Review of Insolvency Practitioner Regulation 2025

Published 7 July 2026

Applies to England, Scotland and Wales

Foreword – Joe Sullivan, Head of Insolvency Practitioner Regulation and Engagement

I am pleased to present the Annual Review of Insolvency Practitioner Regulation for 2025, which sets out the work of the Insolvency Service as oversight regulator, alongside the regulatory activity carried out by the Recognised Professional Bodies (RPBs). We publish this review to support transparency, accountability and proactive engagement with the insolvency profession.

Effective and proportionate regulation is fundamental to a well-functioning insolvency regime. It underpins confidence for individuals, businesses, and creditors and supports wider economic activity by enabling timely, fair and reliable outcomes. Regulation must strike a careful balance by enabling a dynamic and competitive profession to operate and innovate, whilst ensuring the highest professional standards are maintained with prompt action taken where performance falls short.

Insolvency practitioners play a critical role in delivering these outcomes by supporting business rescue, helping individuals address problem debt, and ensuring fair returns to creditors. The vast majority succeed to a high standard, often in challenging circumstances. Our responsibility is to ensure the system recognises and supports that professionalism, while protecting consumers and creditors where it does not.

During 2025, we have continued to strengthen our approach with a sharper focus on outcomes and public confidence which is shaping the future direction of our regulatory work. We have worked closely with the RPBs to ensure that regulatory activity remains effective, consistent and proportionate. We are acting to improve consistency and address poor practice in the Individual Voluntary Arrangement (IVA) market where many customers are vulnerable and in need of protection.

As the Insolvency Service develops towards a more agile organisation focused on delivering economic impact faster, our approach is evolving. Central to this is a shift from oversight of the profession to greater system leadership. This means a more transparent, data-driven and proactive regulatory approach. One that identifies risks earlier, intervenes faster, and drives measurable improvement across the whole insolvency sector.

This will improve outcomes for those in financial distress, strengthen confidence in the insolvency framework, and support a high-performing profession, delivering clear public value for individuals, businesses and creditors. We also need to work in partnership with the sector to ensure regulation is clear, consistent and proportionate, whilst exploring opportunities to reduce unnecessary burdens without placing protections at risk.

I’m grateful for the continued engagement of the RPBs and stakeholders across the profession. By working together to strengthen transparency, consistency and the quality of work carried out by insolvency practitioners, we will continue to build a regulatory system that is trusted, effective and focused on improving the overall experience and outcomes for all our customers.

1. Overview

The Insolvency Service is an executive agency of the Department for Business and Trade (DBT) and helps deliver economic confidence by supporting those in financial distress, tackling financial wrongdoing and maximising returns to creditors.

Acting as oversight regulator of insolvency practitioners on behalf of the Secretary of State for DBT, the Insolvency Service works with the insolvency profession ensuring that professional and regulatory standards are maintained or improved where necessary, and that professional misconduct is addressed.

The Secretary of State, by Order, recognises independent professional bodies, known as the Recognised Professional Bodies (RPBs) for the purpose of authorising individuals to act as insolvency practitioners. Under the provisions of the Insolvency Act 1986, any individual who acts as a liquidator, trustee in bankruptcy, administrator, administrative receiver, a nominee or supervisor of a voluntary arrangement, or a trustee under a trust deed in Scotland must be authorised by an RPB to act as an insolvency practitioner.

In 2025, insolvency practitioners were regulated by three RPBs, in alphabetical order:

• Insolvency Practitioners Association (IPA)
• Institute of Chartered Accountants in England and Wales (ICAEW)
• Institute of Chartered Accountants of Scotland (ICAS)

The Insolvency Service and the RPBs work to achieve regulatory objectives of the insolvency practitioner regime, as set out in the Insolvency Act 1986. These are:

• Having a system of regulating persons acting as insolvency practitioners that secures fair treatment for persons affected by their acts or omissions, reflects the regulatory principles and delivers consistent outcomes.
• Encouraging an independent and competitive insolvency practitioner profession, whose members provide high quality services at a fair and reasonable cost, act transparently and with integrity, and consider the interests of all creditors in any particular case.
• Promoting the maximisation of the value of returns to creditors and the promptness of making those returns.
• Protecting and promoting the public interest.

The Secretary of State has powers to direct or reprimand an RPB if they believe that it is acting in a way that is having an adverse impact on the achievement of the regulatory objectives, and can also, if appropriate, make enquiries and take direct action against insolvency practitioners.

The Insolvency Service also operates the Complaints Gateway in accordance with the Memorandum of Understanding between the Insolvency Service, the Department of Economy of Northern Ireland and the RPBs. The Gateway acts as a single point of contact for making complaints about the conduct of insolvency practitioners, regardless of which RPB they are authorised by. The Insolvency Service monitors the timeliness of complaint handling and outcomes of those complaints.

This report covers the period from 1 January 2025 to 31 December 2025.

2. Legislative, policy, and regulatory developments

The legislative and regulatory frameworks continue to be under review, ensuring that the regime meets its strategic objectives.  During 2025, the regulatory, policy, and legislative landscape saw several significant developments, including ongoing work to update professional and ethical standards and Statements of Insolvency Practice (SIPs), reforms to the bonding regime, and the commencement of work to reform the standard-setting process.

2.1 Regulation and oversight activity

Throughout 2025 we have focused on how we can make insolvency practitioner regulation work better for customers: people who are in debt (and may be vulnerable), creditors, and insolvency practitioners themselves.

Much of this work happens behind the scenes, but it has a direct impact on people’s experience of insolvency. It helps to ensure that insolvency practitioners give clear and accurate information, consistently follow the same standards, and deal with concerns promptly and fairly. It also helps us and the RPBs to focus effort on the areas of greatest risk, so problems can be identified and addressed earlier, and will support our work to ensure further improvements are sustained into 2026.

2.1.1 Development of professional and ethical standards

In 2025, the Joint Insolvency Committee (JIC) continued to develop and maintain the professional and ethical standards that insolvency practitioners must follow. These standards set clear expectations for how insolvency practitioners behave and communicate: helping people in financial difficulty and creditors to have confidence that they will be treated fairly, whilst helping insolvency practitioners understand what expectations and requirements look like in practice.

A key change was an updated Insolvency Guidance Paper (IGP): Dealing with complaints. The RPBs issued the revised guidance on 6 August 2025, effective from 1 October 2025. It replaced the previous version from October 2009, and reflected how much the insolvency landscape, and customer expectations, have changed over that period.

The updated IGP sets out clearer steps for insolvency practitioners to follow when something goes wrong, including what to consider and what actions to take. In practice, it supports faster and more consistent complaint handling, better communication with complainants, and a more proportionate response allowing customers to understand what will happen next and insolvency practitioners to resolve issues without unnecessary delay.

The JIC and the RPBs also approved a revised Code of Ethics (the Code), published on 6 August 2025 and effective from 1 October 2025. The updated Code aligns with international ethical standards set by the International Ethics Standards Board for Accountants and clarifies expectations around professional behaviour, role and mindset. This includes conduct in an insolvency practitioner’s wider professional life. This helps protect customers by reinforcing integrity, objectivity and professional competence, and supports confidence that decisions are being made in the interests of those affected by insolvency.

In the year ahead, we will continue to work with the JIC and the RPBs to support implementation of these updates and to use monitoring, complaints insight, and engagement with stakeholders to understand whether the changes are improving consistency and customer experience in practice.

2.1.2 Review and updating Statements of Insolvency Practice (SIPs)

SIPs set out the standards to which insolvency practitioners are expected to adhere to in key areas of their work. Keeping SIPs up to date helps customers receive a consistent service: clear information, fair treatment and proper handling of their case.

In 2025, the JIC began reviews of SIP 2 and SIP 3.1 and continued its review of SIP 14. The review programme will continue into 2026, with any changes to these SIPs being consulted on. We will use stakeholder feedback and learning from complaints and monitoring to help ensure any updates are practical, proportionate and focused on improving real customer outcomes.

2.1.3 Reform of insolvency standards setting

In 2023, the then Government confirmed its intention for the Secretary of State to take responsibility for setting ethical and professional standards for insolvency practitioners, creating a simpler and more transparent way of setting and reviewing standards, with clearer accountability for how the system works.

In late 2025, the Insolvency Service commenced design work for the new standards‑setting process, including initial scoping, discovery and engagement with stakeholders.

Work will continue during 2026 to prepare for legislative change, and we will work closely with the JIC and the RPBs to ensure continuity as formal responsibilities transition from the JIC to the Insolvency Service.

During 2026 we will also be reviewing the current standard setting framework for insolvency practitioners and how that framework is enforced by the RPBs.

2.1.4 Reforming our approach to performance oversight of the RPBs

During 2025, we introduced a data-led, risk-based approach to monitoring the performance of the RPBs. This involves RPBs providing quarterly data to the Insolvency Service in a consistent format, giving a clear, structured view of their regulatory activity and trends across the framework. The returns include, for example, information on insolvency practitioner licensing, the RPB’s own risk‑rating profiles of their insolvency practitioners, monitoring activity, and complaint volumes and progression. This information helps us to identify emerging themes earlier and to focus oversight activity where it is most likely to support improved outcomes for people in debt and creditors, whilst providing clearer expectations for insolvency practitioners.

We have reviewed the data available for 2025, which has informed our priorities for 2026. As part of this work, we are developing our understanding of the different approaches taken by individual RPBs. Our priorities for the coming year will include:

• how RPBs undertake risk assessment of insolvency practitioners, including the robustness of those processes
• understanding the complaints journey following referral by the Gateway, and how this contributes to disciplinary outcomes
• reviewing the approach taken by RPBs to addressing breaches of anti-money laundering requirements by insolvency practitioners

2.2 Legislation

2025 saw a number of key legislative and system changes that will influence how insolvency practitioners carry out their work and service their customers. As the sector implements these reforms into 2026 our focus will remain on strengthening protections, improving transparency and supporting more consistent outcomes.

2.2.1 Reform of the insolvency practitioner bonding regime

The insolvency practitioner bonding regime provides financial protection where there is a loss arising from dishonesty or failure in the handling of an insolvency, including covering certain costs where a successor insolvency practitioner is appointed.

In 2025, the Insolvency Practitioners (Amendment and Transitional Provisions) Regulations 2024 provided an extended transitional period to help the profession and insurers move to the new requirements. The reforms included:

• a General Penalty Sum increase from £250,000 to £750,000
• stronger minimum statutory bond requirements to cover investigation and successor practitioner costs
• a requirement for a SONIA (Sterling Overnight Index Average) based interest clause
• a minimum six-year indemnity period
• the introduction of a mandatory two-year run-off period
• a requirement to give at least 60 days’ notice before bond expiry or cancellation

Throughout 2025, existing bonds continued to operate under the previous wording while new or renewed bonds were written to reflect the revised requirements. From 1 January 2026, all new bonds were required to comply with the improved provisions.

This strengthens protection for customers and creditors by helping to ensure that sufficient funds are available to support investigation and maintain continuity of the case where a change of office holder is required in defined circumstances, such as where there has been loss or misconduct.

2.2.2 Economic Crime and Corporate Transparency Act 2023 – Companies House reforms

The Economic Crime and Corporate Transparency Act 2023 fundamentally changed the role of Companies House, seeing it move away from being a passive recipient of documents and filings to become a more active and robust gatekeeper of the company registers. Companies House is now able to query filings, annotate the register, and remove recalcitrant companies more quickly, supported by new identity verification requirements and a range of new powers and sanctions.

The continued implementation of Companies House reforms also affects the insolvency profession, including:

• From February 2025, individuals became able to request that residential addresses used as registered office addresses be protected and, from July 2025, to request the suppression of personal information from historical documents. 
• Changes to the Register of Overseas Entities from February 2025 allowed for entities to protect trust member information in certain circumstances. 
• In March 2025, registration commenced for Authorised Corporate Service Providers for individuals or organisations that undertake anti-money laundering supervised activity, such as filing information on behalf of clients and performing identity verification checks. 
• Voluntary identity verification for individuals commenced in April 2025, followed in November 2025 with the transition to mandatory identity verification for all company directors and persons with significant control. 
• In October 2025, The Registrar of Companies (Fees) (Amendment) Regulations 2025 were made, which caused some fees for using Companies House services to increase from 1 February 2026.

Overall, these reforms are intended to improve the reliability of information on the public register to reduce opportunities for misuse and support growth, whilst also helping insolvency practitioners carry out checks and case administration based on more robust information as further changes are implemented into 2026.

2.2.3 Director disqualification and sanctions-related changes

In April 2025, director disqualification sanctions under section 11A of the Company Directors Disqualification Act 1986 and section 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 were extended to apply to persons designated under sanctions legislation.  As a result, a person subject to a relevant sanction is automatically disqualified from acting as a director without having been issued with a specific licence to act.

This prevents individuals subject to sanctions from running UK companies and supports work to improve market confidence and support growth, whilst helping to protect creditors and the wider public.

2.2.4 Changes to Insolvency Service systems and operational delivery

The Insolvency Service implemented a new case management and estate accounting system, INSSight in November 2025, that underpins how we administer insolvency cases and interact financially with the profession.

For insolvency practitioners, INSSight represents a move to a more integrated and transparent platform for estate accounts, payments and statements, replacing a number of legacy systems that were no longer sustainable.

As with any transformation of this scale, the early months required stabilisation, and we have worked closely with practitioners to address issues and prioritise those areas most critical to the profession. Core services are now operating as expected, and the system provides a robust foundation for improving consistency, resilience and digital services over the long term, benefiting both practitioners and the customers they serve.

2.2.5 Official Receivers insolvency practitioner rota

During 2025, the Senior Official Receiver’s Team led the insolvency practitioner re‑accreditation process and, working with Official Receivers and R3 (the UK’s professional and trade body for insolvency and restructuring professionals), moved from a local rota system to a regional rota, with the aim of supporting a more consistent approach to allocating work to insolvency practitioners and helping to ensure cases are handled efficiently.

This aligned with the Insolvency Service’s wider move to regional centres and was completed in Autumn 2025 and will support better experiences for customers and clearer operating arrangements for insolvency practitioners.

2.2.6 Bounce Back Loan cases

The Insolvency Service has continued to take enforcement action where directors had sought to abuse Government-backed Covid financial support schemes.

Insolvency practitioners played an important role in supporting our overall enforcement outcomes in this area of key priority. In respect of Bounce Back Loan cases where an insolvency practitioner was in office, we disqualified 688 directors, at an average disqualification period of 9 years. We also obtained 50 compensation orders and 70 compensation undertakings, with a total value of £4.3 million.

2.3 Case law and legal developments

A number of legal developments of relevance to insolvency practitioners took place in 2025, providing guidance and clarity around how the rules should be applied in real cases, determining what good practice looks like and setting expectations around evidential requirements. For customers this can provide clearer expectations, more consistent decisions, fewer disputes and ultimately more predictable insolvency processes.

2.3.1 Members Voluntary Liquidations – declaration of solvency

In 2025, the RPBs issued joint guidance following the High Court decision in Noal SCSP & Ors v Novalpina Capital LLP & Ors [2025] EWHC 1392 (Ch). At the time of publishing, the judgment is subject to appeal.

2.3.2 Car finance claims

Following the Supreme Court’s judgment in Hopcraft and another v Close Brothers Limited and related cases, the RPBs issued joint interim guidance during 2025 on how insolvency practitioners should approach potential car finance claims in insolvency appointments. The guidance was issued while there remained uncertainty about the scope and operation of any future compensation or redress scheme, as subsequently signalled by the Financial Conduct Authority.

Put simply, the guidance supports a proportionate and consistent approach while the position develops. Pending further clarity, office holders were not expected to undertake proactive investigations into potential car finance claims across their existing or closed personal insolvency cases. This helps avoid unnecessary cost and delay for insolvency estates, while ensuring creditors’ interests are safeguarded. The RPBs will keep this under review and update expectations as further information becomes available.

2.4 Individual Voluntary Arrangements (IVAs)

In 2025, improving how the IVA market works for customers remained a priority for the Insolvency Service and the RPBs. Our focus has been on strengthening oversight and raising standards so that customers considering an IVA receive clear information, fair treatment and services delivered at a reasonable cost, and so that creditors can have confidence that IVAs are used appropriately and deliver sustainable outcomes.

On 1 April 2025, the IVA Standing Committee issued a revised IVA Protocol 2025. The Committee brings together regulators, creditors, insolvency practitioners, representative bodies and debt advice organisations, and is chaired by the Insolvency Service. This collaborative approach helps create clearer and more consistent expectations for how straightforward consumer IVAs should be proposed and managed.

The revised protocol was developed in response to evidence of poor practice identified through regulatory oversight and independent research commissioned by the Insolvency Service and published in October 2024.

The research highlighted weaknesses at the start of the IVA journey: how IVAs were promoted, how suitability was assessed, and whether consumers were given the right information before they agreed to an IVA.

The IVA Protocol 2025 strengthens the framework for administering straightforward consumer IVAs. As a voluntary framework agreed by key stakeholders, it is designed to improve take‑on processes, strengthen consumer protections and support more sustainable arrangements, while setting clearer expectations for how protocol IVAs should be proposed and delivered. The protocol does not change the statutory law on IVAs; instead, it helps make day‑to‑day practice more consistent and transparent.

The key changes introduced by the IVA Protocol 2025 include:

• a new mandatory ‘Key facts’ document that must be given to consumers before they agree an IVA in cases where the Protocol applies, to help them understand the arrangement, the alternatives and likely outcomes. The key facts document is also summarised in an animated video.
• clearer expectations for IVA take‑on, including how suitability should be assessed and what information consumers should receive before entering an IVA.
• clearer guidance on when a protocol IVA may not be suitable, including where an individual may qualify for a Debt Relief Order.
• changes to the treatment of home ownership, confirming that the family home is no longer treated as an asset to be realised; instead, the level of equity helps determine IVA duration, providing greater certainty for consumers and creditors.
• more flexibility for supervisors to manage payment variations within defined limits.
• stronger expectations for termination, including clearer signposting to free, regulated debt advice if an IVA ends.

During 2025, the Insolvency Service continued to work closely with the RPBs, the IVA Standing Committee and other stakeholders to support implementation of the Protocol and to monitor its early impact as part of wider oversight of the IVA market. Looking ahead to 2026, we will use data, stakeholder feedback and complaints insight to understand whether the changes are improving customer outcomes in practice, and to identify where further action may be needed.

In October 2025, the RPBs issued joint guidance on the use of joint nominee agreements in IVAs which took effect from 1 January 2026, in response to concerns about their increasing use in the volume IVA market. The guidance sets out clear expectations for insolvency practitioners involved in these arrangements, emphasising that professional and ethical responsibilities apply equally to both the referring and receiving insolvency practitioner. It also makes clear that joint nominee agreements must not be used in a way that weakens consumer protections or undermines regulatory requirements, including those introduced by the Financial Conduct Authority’s ban on remuneration for debt packagers.

2.5 Changes in RPB Regulations, Procedures and Bye-laws

This section summarises changes the RPBs made in 2025 to their rules, procedures and governance arrangements for regulating insolvency practitioners. These updates matter because they help ensure concerns are handled consistently and fairly, decisions are made transparently, and regulatory action is taken proportionately when standards are not met. For customers, strong and up-to-date regulatory processes support confidence that complaints and misconduct will be addressed effectively and that the system continues to improve.

2.5.1 IPA

Amendments to the IPA Regulatory and Conduct Rules came into effect on 1 April 2025, following approval by the IPA Board on 27 March 2025. The changes updated references within the Rules to ensure consistency with the IPA’s Articles of Association, which took effect on 1 January 2025. The amendments were clarifying in nature and did not result in any substantive changes to regulatory requirements or their application during the period.

All current IPA Regulations are available on IPA’s website here.

2.5.2 ICAEW

ICAEW did not report any changes to its regulations, procedures or bye‑laws during 2025.

All current ICAEW Regulations are available on ICAEW’s website here.

2.5.3 ICAS

During 2025, ICAS implemented a number of changes to its regulatory framework for the regulation of insolvency practitioners. These amendments related to the Investigation Regulations, the Independent Review Regulations, and the Discipline and Appeal Tribunals Regulations.

The Investigation Regulations were amended in March 2025. The changes related to the operation of time limits, the powers of Committees to accept undertakings and impose conditions, and the grounds on which complaints may be rejected at the initial stage of the process by the Director of Investigations.

In May 2025, amendments were made to the Independent Review Regulations, introducing changes to the grounds on which a review may be requested following a Committee decision to reject a complaint. These changes included the introduction of an initial application review by the Chair of the Reviewer Panel. In addition, a minor amendment was made to the Discipline and Appeal Tribunals Regulations in September 2025 to clarify that Tribunals have the power to publicise decisions.

All current ICAS Regulations are available on ICAS’s website here.

2.6 Diversity and Inclusion Steering Group

In 2021, the Insolvency Service partnered with R3, the membership association for restructuring, turnaround and insolvency professionals to discuss, understand and take action to address barriers to inclusion and diversity within the insolvency and restructuring profession.

Since then, the profession has made significant strides in its aims to become a more inclusive and progressive place to work and develop. 

During 2025/26 our action plan focused on the following areas:

• Understanding barriers to progression within the profession and identifying and sharing good practice.
• Promoting the profession as a source of a range of rewarding and interesting careers.
• Improving diversity and inclusion among those taking insolvency qualifications and becoming licensed insolvency practitioners.

We also established a network of Diversity and Inclusion Champions, professionals from across the restructuring and insolvency sector, who are helping to support and share good practice and initiatives from within their own firms.

2.7 Insolvency Practitioner Complaints Gateway

The Complaints Gateway (the Gateway) provides an important service to customers when they are concerned about the service they have received from an insolvency practitioner. 

During 2025, the Gateway received a significantly higher volume of complaints than in previous years. Further data on those complaints is set out in annex A.  A rise in complaints can signal emerging issues in practice, changes in customer awareness, or pressure points in the insolvency system that we and the RPBs need to understand and address.

In response, we have taken steps to improve communication and messaging for potential complainants, including updates to published guidance, to help customers ensure they receive the right information the first time.

Alongside these changes, we are strengthening how we analyse Gateway data so we can better understand what is driving volume changes, to target regulatory attention and preventative work where it will have the greatest impact for customers.

During 2026, we will be transitioning the Gateway to a new case management system to support a more data-driven approach whilst also delivering efficiencies and improvements in the speed and handling of cases. Further work is underway to improve the online complaints form, with a focus on clearer questions and guidance at the point of submission.

Annex A – Annual Review of Insolvency Practitioner Regulation 2025 Statistics

A1: Regulatory and Disciplinary Statistics

This section sets out the regulatory and disciplinary activity during 2025. The statistics provide transparency on how the regulatory system is working in practice by helping the public understand the level of oversight, giving insolvency practitioners clarity on regulatory expectations, and supporting confidence that concerns and misconduct are identified and addressed proportionately.

A1.1 Authorisations

The number of authorised insolvency practitioners provides an overview of the size of the regulated population. Table 1 shows the total number of insolvency practitioners authorised by each RPB as of 1 January, including the number able to take insolvency appointments, showing a comparison between 2025 and 2026.

Table 1: Number of authorised insolvency practitioners (2025-2026)

Year	Category	IPA	ICAEW	ICAS	Total
2025	Total IPs	678	748	77	1504
2025	Appointment takers	587	614	63	1265
2026	Total IPs	637	777	66	1480
2026	Appointment takers	554	655	53	1262

A1.2 Monitoring

Monitoring visits are key activities used by the RPBs to assess whether insolvency practitioners meet the professional and regulatory standards they are required to follow. These visits form part of a risk-based approach and include two types of monitoring: routine monitoring, which are planned visits carried out as part of an RPB’s regular programme, and risk-based/targeted monitoring, which are visits carried out in response to specific risk or intelligence. Table 2 summarises the monitoring visits carried out during 2025.

Table 2: RPB monitoring visits initiated and outcomes of visits completed in 2025

	IPA	ICAEW	ICAS
Routine visits initiated in 2025	227	151	18
Non-routine visits initiated in 2025	5	6	2
Visits completed in 2025 and referred for consideration by relevant committee	11	18	6

*The above table takes into account that some outcomes for 2025 relate to visits that took place during 2024 and that not all outcomes from visits during 2025 have concluded

The IPA operates a Volume Provider Regulation (VPR) Scheme  (the Scheme) for high volume providers of Individual Voluntary Arrangements (IVAs) and Protected Trust Deeds (PTDs). Members of the Scheme are subject to a separate focused monitoring regime in addition to IPA’s regular monitoring programme.

Monitoring visits can result in a range of outcomes depending on the issues identified, from confirmation of satisfactory practice through to referral for committee consideration and / or regulatory action. Table 3 sets out the outcomes recorded following monitoring visits in 2025 that were referred to committees.

Table 3: Outcomes following from visits considered by RPB Committees in 2025

	IPA	ICAEW	ICAS
No action	3	0	1
Undertakings sought from IP	0	3	0
Compliance review	0	8	0
Consent order	8	0	0
Regulatory order	0	13	0
Referral to complaints department	0	10	3
Restriction of licence	0	1	0
Withdrawal of licence	0	1*	0
Other	8	10	3
Total	19	46	7

*Includes one decision to withdraw that remains subject to appeal/review and is therefore not yet final; accordingly, it is not included in Annex B - Sanctions.

A1.3 Regulatory and Disciplinary Outcomes

Regulatory and disciplinary action taken by RPBs continues to form a critical part of their work in meeting the regulatory objectives, as it provides assurance that insolvency practitioners are held to account where standards are not met and that appropriate and proportionate action is taken to address misconduct or poor professional practice. It is important that standards are applied and upheld consistently across the marketplace and we remain vigilant in our capacity as oversight regulator to ensure high standards are maintained. Such action helps to protect the public interest, maintain confidence in the insolvency regime, and reinforces the importance of compliance with professional, ethical and statutory requirements across the profession.

Whilst representing a small percentage of the profession, the data relating to sanctioning for 2025 demonstrates the important steps taken by the RPBs and their relevant committees.

Similarly to monitoring visits, regulatory and disciplinary action may lead to a number of different individual outcomes.

Table 4 summarises the disciplinary and regulatory outcomes issued during 2025, including whether they were published and the extent to which they involved an impact on an insolvency practitioner’s licence.

Table 4: Sanctions during 2025

Category	IPA	ICAEW	ICAS
Published outcomes*	27	26	1
Formal warnings (published anonymously)	5	0	0
Licence impact
Suspension/restriction	0	-	0
Exclusion/withdrawal	1	1**	0

*Includes disciplinary consent, regulatory penalties and cautions.

**Includes one decision to withdraw that remains subject to appeal/review and is therefore not yet final; accordingly, it is not included in Annex B - Sanctions.

A2 Complaint Statistics

Complaints data is an important indicator of customer experience and potential risk in the system. In this chapter, we explain what we received during 2025, what we did in response, and what the trends may mean for the Gateway and the wider regulatory framework going forward.

A2.1 Insolvency Practitioner Complaints Gateway Statistics

The Gateway is the principal route by which concerns about insolvency practitioners are submitted. The tables in this section provide an overview of Gateway activity during 2025, including volumes received and the outcome of initial assessments.

Only complaints that fall within the Gateway’s remit, and which indicate an issue that may require regulatory consideration are referred to the relevant RPB. Each submission is initially triaged by the Gateway to assess whether the information and evidence provided indicate conduct likely to meet the threshold for disciplinary action by the RPB, or whether the matter should be rejected or closed.

A complaint may be closed where it cannot be progressed to an assessment decision. This includes cases where requested evidence or information is not provided within the required timeframe, where the matter raised is not about an insolvency practitioner, or where the complaint is withdrawn. The Gateway may also close a complaint where the complainant is directed to pursue the firm’s own complaints process first, or where the issue has already been through an appropriate complaints route.

The Gateway received 966 complaints which represented a 47% increase on the 656 received in 2024.

Table 5: Complaints received by the Gateway

Complaints	2025	2024
Total new complaints received in 2025	966	656
Total complaints referred to the RPBs in 2025	166	144
Total complaints rejected or closed in 2025	826	412
Ongoing	61	100

*The totals for referred and rejected or closed reflect all cases handled during 2025, including complaints brought forward from 2024, and therefore differ from the number of complaints received in 2025.

Table 6: Number of referrals made to RPBs

RPB	2025
IPA	125
ICAEW	33
ICAS	8
Total	166

Table 7: Referrals by insolvency procedure

Insolvency procedure	2025	%
Individual voluntary arrangement (IVA)	75	45%
Liquidation	49	30%
Administration	21	13%
Bankruptcy	16	10%
Trust Deed	3	1%
Sequestration	2	1%

Table 8: Referrals by subject matter

Subject matter	2025	%
Communication breakdown	62	37%
Competence and due care	43	26%
SIP 3 (Individual and company voluntary arrangements)	30	18%
Other	13	8%
SIP 1 (Fundamental Principles)	9	5%
Behaviour	6	4%
SIP 2 (Investigations by office holders)	1	1%
SIP 9	1	1%
Conflict of interest	1	0%
Total	166	100%

 

Table 9: Gateway complaint referrals by complaint source

Complaint source	2025	%
Debtor	57	34%
Creditor	56	34%
Director	17	10%
Employee	9	5%
Debtor’s friend/family	8	5%
Other	8	5%
Insolvency practitioner	6	4%
Debt advisor	3	2%
Shareholder	1	1%
Accountant in Bankruptcy (AiB)	1	0%
Total	166	100%

Table 10: Reasons for rejection of Gateway complaints

	2025	%
Effect of insolvency	99	33%
Other*	93	31%
Commercial matter	60	20%
Director’s conduct	31	10%
Conduct over three years	15	5%
Actions of third party	3	1%
Total	301	100%

*Other continues to represent a comparatively high proportion of rejections. We are working to better understand the types of issues being captured within this category. This review will help inform future reporting and overall improvements to the complaints process, improving transparency and providing a clearer picture of complaint trends.

Table 11: Reasons for closure of Gateway complaints

	2025	%
Asked to complain to IP first	285	54%
Other	105	20%
No response to request for evidence/ information	76	14%
Complaint not about an IP	34	6%
Complaint withdrawn	13	3%
Already been through the complaint process	12	3%
Total	525	100%

A2.2 Complaints Progression

Table 12 summarises the number of complaints currently open with each RPB and a overview of the age profile of those cases. These complaints are often complex and may vary significantly in scope and duration. Progress can be influenced by a range of factors, including the nature of the issues under investigation and the complexity of the cases.

Looking ahead, we will continue to work collaboratively with the RPBs to enhance alignment in how complaints are recorded, reported and tracked, so that trends can be more clearly understood and addressed across the sector.

Table 12: Complaints open with the RPBs

RPB	Total open complaints	Complaints open: 12 months to 2 years	Complaints open: over 2 years
IPA	122	24	9
ICAEW	97	45	6
ICAS	12	2	1

A2.3 Complaints about RPBs

As the oversight regulator, the Insolvency Service also considers complaints about the RPBs and how they carry out their regulatory functions. This may include how they handled a complaint about an insolvency practitioner. Our role is not to reinvestigate the original complaint, but to check whether the RPB followed its own procedures, applied its processes fairly and consistently, and acted in a way that supports the regulatory objectives.

Where we identify issues, we may make recommendations to the RPB on improvements. This may include changes to guidance, training or quality assurance. The aim is to support better and more consistent complaint handling over time, so that concerns are dealt with promptly and transparently and confidence in the regulatory system is maintained.

Table 13: Complaints received about RPBs during 2025

Complaints	IPA	ICAEW	ICAS
Carried Forward from 2024	1	0	0
Received	0	1	0
Rejected	1	0	0
Closed/withdrawn	0	0	0
Ongoing	0	1*	0

• The ICAEW complaint relates to a case received by the Insolvency Service in 2025; the ICAEW was made aware in March 2026

Annex B - Sanctions

Summary of regulatory and disciplinary sanctions issued and accepted in 2025

A detailed explanation of the Fundamental Principles referred to in the table below is provided in the Insolvency Practitioner’s Code of Ethics.

Sanctions are publicised by the RPBs and also by the Insolvency Service. In exceptional circumstances, a decision may be made by the relevant Committee not to publish, or to anonymise, the details of a sanction. Less serious outcomes, such as formal warnings are also published on an anonymous basis by some RPBs.

Details of regulatory and disciplinary sanctions are available on the official government website, gov.uk, which provides public access to information on insolvency practitioners and associated regulatory and disciplinary outcomes.

Further details of individual sanctions can be found on the RPB’s websites:
IPA Enforcement Notices

ICAEW Disciplinary Database

ICAS Disciplinary Notices

The list below is arranged by the type of sanction, then alphabetically by the RPB, and then alphabetically by the name of the insolvency practitioner.

In line with our data protection policy, this annex is anonymised after 2 years.

Exclusions and withdrawals/revocations of licence

RPB	IP	Sanction	Reason
IPA	Patricia Marsh	Withdrawal of Licence	Failure to maintain adequate records to explain the administration of cases and decisions taken; failure to submit timely bordereaux returns; numerous failures to produce and file statutory reports and failures to bring outstanding reports up to date; failure to manage, investigate and progress cases in a timely manner; failure to respond to and co-operate with the IPA Secretariat during the inspection process.

Severe reprimand

RPB	IP	Sanction	Reason
IPA	Andrew Ryder	Severe Reprimand Fine: £5,000 Costs: £1,337.50	A breach of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR2017) when the IP, in his role as Liquidator of a company, a) failed to sufficiently identify and verify the customer’s identity as required by Regulation 28 of the MLR2017; and b) failed to verify the identity of the customer and any beneficial owner of the customer before a business relationship was established, or a transaction carried out as required by Regulation 30 of the MLR2017.
IPA	Anthony Hyams	Severe Reprimand x 3 Fine: £20,000 Costs: £15,250	Allegation 1: A breach of the Fundamental Principle of Professional  Competence and Due Care of the Insolvency Code of Ethics and Section 330 of the Proceeds of Crime Act 2022 when, between 4 November 2021 and 13 December 2022, the IP in his role as liquidator, having reasonable grounds for knowing or suspecting that another person and another entity were engaged in money laundering  failed to make the required disclosure to a nominated officer as soon as practicable after he received the information. Allegation 2: as Liquidator a company A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics and Statement of Insolvency Practice (SIP) 2 and SIP 1 when the IP a. failed to conduct timely and appropriate investigations into the affairs of the company and its director b. failed to take timely and appropriate action as a result of information which came into his possession. c. failed to document appropriately his strategies, decision-making processes, investigations and conclusions. Allegation 3: A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics and Section 7A (1), 7A (3) and 7A (5) of the Company Directors Disqualification Act 1986 (CDDA), when the IP a. submitted, to the Secretary of State and the Director Conduct Reporting Service, a conduct report on the director that was materially misleading. b. failed to send new information, that should have been included in the conduct report in relation to the company and director, to the Secretary of State and the Director Conduct Reporting Service as soon as reasonably practicable.
IPA	Clive Morris	Severe Reprimand Fine: £7,500 Costs: £5,530	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP: a. failed, in a liquidation, to apply any or adequate customer due diligence measures before carrying out a financial transaction in breach of regulation 27(1)(b), and 28 and 30(2) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 [“MLR17”]; and b. failed, in three insolvency estates, to have sufficient records to show and explain the administration of the case and any material decisions made in breach of regulation 13(1) of The Insolvency Practitioners Regulations 2005:and c. failed in three cases to conduct sufficient investigation into the company and failed to have sufficient records to evidence the investigations that were carried out on the file in breach SIP 2; and d. Failed to progress one Liquidation estate in a timely manner; and e. 1) In no less than 164 Voluntary Liquidations, in around 335 separate instances, failed to deliver a copy of a progress report to the Registrar of Companies and/or to members and/or to creditors within two months after the end of the period covered by the report in breach of rule 18.7(6) Insolvency (England and Wales) Rules 2016; and ii) In no less than 15 Voluntary Liquidations, in around 53 separate instances, failed to deliver a copy of any progress report to the Registrar of Companies and/or to members and /or to creditors in breach of rule 18.7(6) Insolvency (England and Wales) Rules 2016.
IPA	Daniel Plant	Severe Reprimand Fine: £5,000 Costs: £2,485.50	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP, in his role as liquidator of a company: a) Failed to respond to correspondence from the company’s pensions administrator; and b) Failed to ensure complete and accurate Forms RP15 and RP15A were submitted to the  Redundancy Payments Service as appropriate prior to the closure of the case.
IPA	David Hughes	Severe Reprimand & Reprimand Fine: £6,500 Costs: £900	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP; Allegation 1: a) failed to submit monthly bordereau returns to the IPA in accordance with The Insolvency Practitioner Regulations 2005;  b) he failed, in his role as liquidator of one company, to: 1. publish a notice of his appointment in the Gazette and deliver a notice of his appointment to the Registrar of Companies in breach of S109(1) Insolvency Act 1986; 2. advertise a notice of intention to declare a dividend in breach of Rule 14.28 Insolvency Rules (IR) 16; 3. deliver notice of intention to declare a dividend in breach of Rule 14.29 IR 16. c) In his role as liquidator of three companies, failed to file progress reports within two months of the period end in breach of Rules 18.7 (6) and 18.8 (5) IR16. e) In his role as liquidator of one company he failed to: 1. progress the liquidation in a timely manner; 2. file notice of his appointment with Registrar of Companies as soon as reasonably practicable in breach of Rule 4.106A (4) the Insolvency (Amendment) Rules 2010; 3.  advertise and deliver a notice of intention to declare a dividend in breach of Rule14.28 and Rule 14.29 IR 16. f) In breach of Rule 18.7 (6) IR16, he failed to: 1. prepare or send annual progress reports to the Registrar of Companies in no less than eight cases: 2. issue 19 annual progress reports (across no less than 13 cases) in a timely manner. g) In his role as supervisor of an Individual Voluntary Arrangement (IVA) he failed to: 1.  to pay an equalising dividend in a timely manner, and 2. to distribute funds in accordance with the IVA proposal. Allegation 2: A failure on two cases, contrary to the provisions of Statement of Insolvency Practice (SIP) 11, to have appropriate safeguards in place to clearly differentiate and segregate estate money, client money and the money belonging to the entity in which he was working.
IPA	David Hughes	Severe Reprimand Fine: £8,000 Costs: £2,850	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP: 1. In his role as liquidator of three companies, failed to bond the cases in accordance with Part 2, Paragraph 3 of The Insolvency Practitioner Regulations 2005 (as amended); and/or 2. In his role as liquidator of the companies referred to above (at part 1) and a further three companies, he: a. recharged bond costs that had not been incurred, and b. in respect of three of the cases, he withdrew funds from the liquidation account for bond costs that had not been incurred.
IPA	Donald McKinnon	Severe Reprimand x 2 Fine: £6,500 Costs: £1,712.50	1.  A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics when the IP failed to undertake proportionate investigations into the affairs of three companies in breach of paragraph 4a of Statement of Insolvency Practice (‘SIP’) 2 and failed to document his assessments, investigations, and conclusions in respect of his investigations into the affairs of three companies in breach of paragraph 18 of SIP 2. 2.  A breach of the Fundamental Principle of Professional Behaviour of the Insolvency Code of Ethics when he took almost five years to issue a dividend to creditors.
IPA	Dylan Quail	Severe Reprimand Fine: £7,500 Costs: £2,307.50	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics when the IP, whilst acting as Supervisor of two Individual Voluntary Arrangements:   1. failed, in one IVA case, to close the IVA promptly once the debtor had satisfied their obligations under its terms; in breach of paragraph 16(j) SIP 3.1 dated 1 July 2014; and 2. on the second IVA, allowed a variation to the debtor’s original IVA Proposal to be put to creditors without first assessing whether it had a reasonable prospect of being implemented.
IPA	Emily Ball	Severe Reprimand Fine: £5,000 Costs: £2,425	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP, in her role as liquidator of 12 companies and administrator of three companies, failed to file no less than 18 progress reports within the requisite time frame in breach of Rule 18.6 (4) Insolvency Rules 2016 (IR16) and/or Rule 18.8(5) IR16 and/or Rule 18.7 (6) IR16.
IPA	Ian Rose	Severe Reprimand Fine: £6,000 Costs: None	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP failed to comply with section 256A(3) (a) and (b) of the Insolvency Act 1986 and Statement of Insolvency Practice 3.1 paragraphs 10, 14 and 15 by: a) wrongly certifying that an Individual Voluntary Arrangement (IVA) proposal had a reasonable prospect of being approved and implemented and should be considered by the debtor’s creditors when on the information, available to him, it was not possible to properly reach such a conclusion; and b) wrongly opposing the petitioning creditor’s application to set aside the IVA, rather than taking a neutral stance between the petitioning creditor and the debtor.
IPA	Jason Callender	Severe Reprimand Fine: £3,000 Costs: £6,600	A breach of the fundamental principles of Objectivity and Professional Behaviour of the Insolvency Code of Ethics, when, knowing that a senior colleague and majority shareholder had caused a valuation report on two properties to be falsified and placed on the IP’s receivership case files, chose to continue to have a business and/or professional relationship with that person.
IPA	Jeff Brenner	Severe Reprimand Fine: £10,000 Costs: £750	A breach of Section 331 of the Proceeds of Crime Act 2002, when the IP, acting in contemplation of his appointment as Liquidator and/or Liquidator of numerous companies, having grounds for knowing or suspecting that another person was engaged in money laundering, failed to make the required disclosures to the National Crime Agency.
IPA	Joseph Sadler	Severe Reprimand Fine: £5,000 Costs: £1,037.50	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics when the IP, in his role as Liquidator of two companies, took more than five years to pay a distribution to creditors when funds were available to do so.
IPA	Kenneth Pattullo	Severe Reprimand x 2 Fine: £14,000 Costs: £450	1. A breach of Statement of Insolvency Practice (‘SIP’) 2, when the IP, in his role as liquidator of a company: • Failed to conduct investigations that were proportionate to the circumstances of the case as required by paragraph 4; and • Failed to enquire whether prior transactions by the company could give rise to an action for recovery as required by paragraph 8; and • Failed to adequately document initial assessments, investigation, and conclusions, including any decision that further investigation or action was not required or feasible as required by paragraph 18. 2. A breach of S330 of the Proceeds of Crime Act 2002 (‘POCA2002’) when the IP, in his role as liquidator of a company, failed to report a suspicion of criminal conduct to his firm’s Money Laundering Reporting Officer (MLRO).
IPA	Margot McLennan	Severe Reprimand Fine: £6,500 Costs: £450	A breach of Regulations 27 & 28 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (‘MLR17’) when the IP, in her role as Liquidator of no less than one case, failed to carry out customer due diligence and assess the risk of money laundering prior to the establishment of the business relationship and acceptance of funds from the company.
IPA	Martin Halligan	Severe Reprimand x 2 Fine: £20,000 Costs: £12,700	1. A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics and Statement of Insolvency practice (SIP) 2 by failing to conduct timely and appropriate investigations into the affairs of the company, its director and de facto director, on two cases. 3. A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics and section 7A Company Directors Disqualification Act 1986 by: a. submitting to the Director Conduct Reporting Service a report which was materially misleading, b. failing to update the Director Conduct Reporting Service when further material evidence came to his knowledge. 4. breached the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics and Section 330 Proceeds of Crime Act 2002 by failing to report Suspicious Activity to his Money Laundering Reporting Officer (MLRO).
IPA	Neil Gibson	Severe Reprimand Fine: £4,000	Costs: £450	A breach of Section 331 of the Proceeds of Crime Act 2002, when the IP, in his role as Liquidator of two companies, having grounds for knowing or suspecting that another person was engaged in money laundering, failed to make the required disclosure as soon as reasonably practicable after the information came to him.
IPA	Nicholas Barnett	Severe Reprimand x 2 Fine: £10,000 Costs: -	A breach of the fundamental principle of professional competence and due care of the Insolvency Code of Ethics when the IP, in his capacity as Office Holder of no less than 79 insolvency estates, failed to prepare and/or file progress reports at Companies House either at all, or by the statutory deadline.
IPA	Paul Johnson / Paul Keeley	Severe Reprimand Fine: £7,500 Costs: £450	A breach of R340.04 of the Insolvency Code of Ethics, when between 02.10.2023 and 17.10.24, the IPs paid for the introduction of 230 Individual Voluntary Arrangement appointments
IPA	Phillip Roberts	Severe Reprimand x 2 Fine: £10,000 Costs: £1,800	Allegation 1. A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics when the IP, in his role as Liquidator of no less than 17 Creditors’ Voluntary Liquidations, failed to submit conduct reports to the Insolvency Service within three months of his appointment. Allegation 2. A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP in his role; a) as Trustee in Bankruptcy, failed to progress the administration of the estate in a timely manner; b) as Administrator failed to; - progress the Administration in a timely manner; - to file with the registrar of companies 14 receipts and payments accounts within the prescribed period; c) as Trustee in Bankruptcy, failed to make adequate enquiries relating to the sale of the bankrupt’s business and to progress the administration of the estate in a timely manner; d) as Liquidator, failed to progress the Liquidation in a timely manner; e) as potential Liquidator, failed to carry out sufficient due diligence to ascertain the financial position of the company and, thereafter, as Liquidator failed pursuant to Section 95 of the Insolvency Act 1986 to convert the Liquidation to a Creditors Voluntary Liquidation when he had reasonable grounds to form the opinion that the company was insolvent; f) as Trustee in Bankruptcy, failed to progress the administration of the estate in a timely manner; g) as Liquidator, failed in no less than 34 Creditors Voluntary Liquidations to deliver progress reports to the Registrar of Companies, within two months after the period end dates. h) as Liquidator, failed in no less than 7 Members Voluntary Liquidations to deliver to the Registrar of Companies and advertise in the London Gazette required post appointment notifications, within the prescribed time limits; and i) as Liquidator of two companies, failed to advertise his appointment in the London Gazette, and to deliver to the Registrar of Companies notice of his appointment as soon as reasonably practicable.
IPA	Simon Plant	Severe Repriman Fine: £5,000 Costs: £4,822.50	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP, in his role as Administrator of two companies a) Failed to address correspondence from the companies’ pensions administrator; and b) Failed to ensure complete and accurate Forms RP15 and RP15A were submitted to the Redundancy Payments Service as appropriate prior to the closure of the cases.
IPA	Stuart Rathmell	Severe Reprimand Fine: £5,000 Costs: £450	A breach of the Fundamental Principle of Professional Behaviour of the Insolvency Code of Ethics when the IP failed to comply with a condition placed on his licence prohibiting him from accepting more than eight new appointments per calendar month.
ICAEW	Alan John Clark	Severe Reprimand Fine £3,500 Costs £3,200	As liquidator of one company failed to report Covid financial support scheme fraud to the Directors Conduct Reporting Service in breach of SIP 2.
ICAEW	Duncan Swift	Severe Reprimand Fine £10,000 Costs £15,040	As Trustee in bankruptcy: - facilitated an engagement letter to be issued which created a conflict of interest - failed to recognise the conflict that had been caused and compromised his business judgement - granted a licence to occupy when he did not have sufficient right or title to do so in breach of Section 120 of the Code of Ethics
ICAEW	Julie Ann Swan	Severe Reprimand Fine £7,500 Costs £5,170	As Joint Liquidator, failed to act in accordance with the Fundamental Principle of Professional Competence and Due Care by failing to take account of information provided to her in an email, when calculating and making a first cash distribution to the Company’s shareholders.
ICAEW	Lisa Ion	Severe Reprimand Fine £6,000 Costs £12,412	In respect of 9 companies in liquidation failed to take reasonable steps to ensure that RP15 forms were submitted as soon as was reasonably practicable as required by Section 125(3) of the Pension Schemes Act 1993 in breach of the fundamental principle of Professional Competence and Due Care.
ICAEW	Mark Littleton-Grey	Severe Repriman Fine £5,000 Costs £7,258	1.Failed to identify that estate monies were not held in an account where funds are readily identifiable to each separate estate, in breach of SIP 11.2. As Nominee in one IVA failed to correctly disclose assets: a) in accordance with Paragraph 6 of SIP 3.1 in relation to the Proposals b) in accordance with Paragraph 6 of SIP 3.1 in his Nominee Report c) in accordance with Rule 8.5(1) of the Insolvency Rules 2016
Both in breach of the fundamental principle of Professional Competence and Due Care
ICAEW	Megan Wallis	Severe Reprimand Fine £4,000 Costs £15,241	As Trustee in Bankruptcy and liquidator of three companies failed to take reasonable steps to ensure the cases were progressed in a timely way in breach of the fundamental principle of Professional Competence and Due Care.
ICAEW	Muhammad Usman Nazir	Severe Reprimand Fine £5,000 Costs £8,095	As Liquidator failed to conduct investigations in accordance with Paragraph 8 and 9 of SIP 2, in breach of the fundamental principle of Professional Competence and Due Care.
ICAEW	Philip Barrington Wood	Severe Reprimand Fine £11,600 Costs £13,105	As sole Trustee in Bankruptcy: 1    Failed to conduct an adequate review which led to a failure to identify that there was a Capital Gains Tax liability due to HMRC. 2A&B    When preparing to issue a Notice of Intended Dividend failed to consider the financial circumstances of the bankruptcy estate, as a result,  failed to comply with Rule 14.34 and failed to include all of the information required under paragraph (3) of Rule 14.35 of the Insolvency Rules 2016 3A&B   Failed to deliver the annual progress report covering two reporting periods within two months, as required by Rule 18.8 of the Insolvency Rules 2016.
ICAEW	Richard Cacho	Severe Repriman Fine £19,750 Costs £30,300	As Office Holder of three connected entities failed to: - Take reasonable steps to identify and evaluate whether the trading strategy would be of benefit to creditors and whether the licences and permits held allowed continuation of trade. - Failed to produce and/or maintain trading cashflow statements and profit and loss accounts to demonstrate the actual trading position for one entity - Failed to maintain estimated outcome statements to account for changes in circumstances - Failed to obtain sufficient or act on professional advice in relation to executing a private sale treaty - Failed to comply with S188 and/or 193 of TULRCA 1992 by failing to conduct collective consultation or submit the HR1 form to the RPS for one entity - Failure to comply with Section 3 of the Pensions Act 2008 in respect of auto enrolment obligations for one entity - Failed to report complete information to creditors in breach of Rule 18.3 Insolvency Rules 2016 for three reporting periods for all three entities - Failed to produce a separate trading account in breach of SIP 7 in the proposals and two progress reports for one entity - Failed to apply to Court to end the Administration in accordance with S79(2)(a) Sch B1 IA 1986 for two entities.

Reprimands

RPB	IP	Sanction	Reason
IPA	David Rankin	Reprimand Fine: £1,500 Costs: £1,980	A failure to comply with paragraph 18 (a) Statement of Insolvency Practice (SIP) 3.1 (effective 1 March 2023) when staff acting on the IP’s behalf, incorrectly advised the debtor that they were not eligible for a Debt Relief Order.
IPA	Dylan Quail	Reprimand Fine: £2,000 Costs: £2,700	A breach of the fundamental principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP took approximately 15 months to issue a certificate of completion following the full and final settlement of the IVA.
IPA	Ian Royle	Reprimand Fine: £2,000 Costs: £3,585	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP, in his role as liquidator of a company: a) Failed to ensure that the information provided in Form RP15 was consistent with the company’s records; b) Submitted Form RP15 despite forming the initial view that pension liabilities had transferred to the purchaser of the company’s assets, a transaction that occurred prior to Mr Royle’s involvement, and c) Failed to address certain correspondence from the company’s pensions administrator resulting in the outstanding pension contributions not being finalised prior to the closure of the liquidation.
IPA	Michael Sloper	Reprimand Fine: No fine Costs: £2,350	A breach of the Fundamental Principle of Professional Competence and Due Care of the Insolvency Code of Ethics, when the IP failed to correctly advise two debtors of their suitability to enter a Debt Relief Order.

Other disciplinary penalties

RPB	IP	Sanction	Reason
IPA	IPA Member	Formal Warning Fine: N/A Costs: £1,425	A breach of the fundamental principle of Competence and Due Care of the Insolvency Code of Ethics, when the IP, as trustee of bankruptcy: (i) in breach of Rule 18.8 of the Insolvency Rules 2016, failed to deliver no less than three progress reports within two months of the end of the period covered by the report (ii) in breach of Rule 10.87 of the Insolvency Rules 2016, issued a final report that did not include the required information in breach of Rule 18.30 of the Insolvency Rules 2016, drew fees exceeding the amount approved by creditors.
IPA	IPA Member	Warning	A breach of paragraph 18 of Statement of Insolvency Practice (SIP) 2, when the IP failed to document the scope of his investigations and conclusions reached.
IPA	IPA Member	Warning	A breach of the fundamental principle of professional competence and due care of the Insolvency Code of Ethics, when the IPs failed to have adequate controls in place to: 1. Correctly extend the Administration, and/or 2. File documents at Companies House by the statutory deadlines.
IPA	IPA Member	Warning	A breach of the Insolvency Code of Ethics paragraph 4(c) fundamental principle of professional competence and due care, and/or a failure to comply with the principles of Statement Insolvency Practice (SIP) 3.1 when, the IP: 1) failed to ensure that a full and proper assessment was made of the debtors’ individual circumstances, and/or 2) failed to ensure that the debtors received appropriate advice in relation to a Debt Relief Order (DRO) in breach of SIP 3.1 when staff acting on his behalf, incorrectly advised both debtors that they could not enter into or were not eligible for a DRO when at least one of the debtors would have qualified for that option.
ICAEW	James Richard Clark	Caution	Failed to comply with the fundamental principle of confidentiality by asking employees of one entity to print, scan and return to him information relating to a separate entity.

Regulatory penalties accepted in 2025

RPB	IP	Sanction	Reason
ICAEW	Samantha Hawkins	Regulatory penalty of £5,000	Including 56 days annual leave on forms RP14/A for the director’s daughter without verification and without informing RPS it was unverified
ICAEW	Elgin Faik	Regulatory penalty of £7,500	Delay in progressing investigation work in relation to paying a dividend to creditors.
ICAEW	Paul Appleton	Regulatory penalty of £7,500	Delay paying preferential dividend
ICAEW	Asher Miller	Regulatory penalty of £7,500	Delay paying preferential dividend
ICAEW	Simon Gwinnutt	Regulatory penalty of £4,500	Breach of a restriction
ICAEW	Simon Gwinnutt	Regulatory penalty of £4,500	Deficiencies in fee request
ICAEW	Nicholas Stratten	Regulatory penalty of £2,000	Unauthorised remuneration
ICAEW	Nicholas Stratten	Regulatory penalty of £5,000	Failure to comply with SIP 16
ICAEW	Simon Hicks	Regulatory penalty of £4,000	Claiming for unverified holiday pay
ICAEW	Matthew Hoy	Regulatory penalty of £5,000	Not insuring or restricting properties
ICAEW	Catherine Varney	Regulatory penalty of £12,000	Breaches of SIP 3.1
ICAEW	Gary Pettit	Regulatory penalty of £2,500	Delay in paying a dividend
ICAEW	Gary Pettit	Regulatory penalty of £5,000	Failure to comply with SIP in drawing unauthorised remuneration
ICAEW	Hasib Howlader	Regulatory penalty of £6,000	Delays in dealing with pension obligations
ICAEW	Nathan Jones	Regulatory penalty of £3,000	Not insuring a property
ICAEW	Arvindar Jit Singh	Regulatory penalty of £1,500	Unauthorised remuneration
ICAS	Derek Grant	Regulatory penalty of £5,000	Failed to close a number of insolvency cases