Regulatory Law
Accountants & Actuaries

We handle regulatory cases where accountants and actuaries are being investigated by the Institute of Chartered Accountants in England and Wales (ICAEW), the Chartered Institute of Public Finance and Accountancy (CIPFA), the Association of Chartered Certified Accountants (ACCA), the Chartered Institute of Management Accountants (CIMA), and the Institute and Faculty of Actuaries (IFoA).

The Regulatory Process

In the United Kingdom, accountants and actuaries are subject to disciplinary regulation by their respective professional bodies and, in certain cases, by the Financial Reporting Council (FRC). The FRC operates three enforcement frameworks: the Audit Enforcement Procedure (AEP), which deals with breaches of statutory audit requirements; the Accountancy Scheme, which addresses misconduct by accountants and accountancy firms in qualifying public-interest cases; and the Actuarial Scheme, which deals with misconduct by individual actuaries in qualifying public-interest cases. Other disciplinary matters are generally dealt with by the relevant professional body.

The FRC’s Accountancy and Actuarial Schemes were updated with effect from 1 March 2026, while a revised Audit Enforcement Procedure came into force on 1 July 2026. The revised AEP introduced three additional mechanisms for resolving cases — Published Constructive Engagement (PCE), the Accelerated Procedure (AP) and the Early Admissions Process (EAP) — alongside the existing settlement arrangements. These procedures provide greater flexibility in addressing regulatory concerns, allowing certain matters to be resolved through remediation, early admissions or accelerated proceedings without requiring a fully contested disciplinary hearing.

Where a complaint or concern is raised, the matter will initially be assessed to determine whether it falls within the jurisdiction of the relevant professional body or the FRC. Cases may be referred to the FRC by professional bodies or identified through its own enquiries. Under the Accountancy and Actuarial Schemes, the FRC’s Board or Conduct Committee determines whether the applicable criteria for commencing an investigation are satisfied, including whether the matter raises important public-interest issues and whether there are reasonable grounds to suspect misconduct.

Where an investigation is commenced, the matter is referred to Executive Counsel, supported by lawyers, forensic accountants and other specialists where appropriate. Evidence may be obtained from the accountant or actuary concerned, their employer, professional bodies, witnesses and other relevant sources. At the conclusion of the investigation, Executive Counsel will consider whether there is a realistic prospect of an adverse finding and whether a disciplinary hearing is desirable in the public interest. Under the Accountancy and Actuarial Schemes, where a Proposed Formal Complaint is issued, the accountant or actuary will normally have eight weeks to submit representations before a decision is made on whether to commence formal disciplinary proceedings.

Where formal proceedings are brought under the Accountancy or Actuarial Scheme, the matter may be referred to an independent Disciplinary Tribunal. At the hearing, the accountant or actuary is entitled to be legally represented, make representations, call witnesses and submit evidence in their defence. The Tribunal will consider the evidence and determine whether misconduct has been established. Where an adverse finding is made, the Tribunal may impose an appropriate sanction. Alternatively, proceedings may be resolved through an agreed settlement, subject to the applicable approval procedures.

Under the Audit Enforcement Procedure, the FRC may investigate breaches of statutory audit requirements by auditors and audit firms. The revised procedure provides additional routes to resolution, including an Early Admissions Process, under which an investigation subject may undertake a review of its own conduct and make admissions that form the basis of an agreed settlement, and an Accelerated Procedure, which allows the FRC to propose findings and sanctions based on information already available. Where allegations are contested and cannot otherwise be resolved, the matter may proceed to an independent tribunal for determination.

Where misconduct or a breach of relevant professional requirements is established, sanctions may include reprimands, severe reprimands, financial penalties, conditions or restrictions on professional practice, requirements concerning training, suspension or withdrawal of practising authorisations, and exclusion from membership of the relevant professional body. Financial penalties imposed under the applicable FRC enforcement frameworks may be unlimited. Depending on the circumstances, sanctions may also include the waiver or repayment of client fees, restrictions on undertaking particular activities, or prohibition from conducting statutory audits. The precise sanctions available depend on the nature of the proceedings and the rules governing the relevant enforcement framework.

An accountant or actuary may appeal against certain disciplinary findings or sanctions in accordance with the procedures governing the relevant professional body or FRC enforcement scheme. Under the FRC’s Accountancy Scheme, an appeal against an adverse finding or sanction of a Disciplinary Tribunal must normally be initiated within 28 days of notification of the decision. Appeals are subject to specified grounds, including errors of law, serious procedural irregularities, relevant new evidence or a manifestly unreasonable sanction, and require permission to proceed. Different appeal procedures may apply under the Audit Enforcement Procedure, Actuarial Scheme and the disciplinary arrangements of individual professional bodies.

Internal Disciplinary Proceedings

We also assist and represent accountants and actuaries where they are the subject of internal disciplinary proceedings by their employer.

What To Do If Regulatory Proceedings Are Commenced Against You

Should internal disciplinary proceedings or FRC or other regulatory proceedings be commenced against you, then please either telephone us on 0333 301 0700, or complete our questionnaire.