Westminster Policy News & Legislative Analysis

Bounce Back Loans: Enforcement Results and Insolvency Plan 2026–31

Government figures released this year give a clearer view of where pandemic-era support ended up and how enforcement is being reshaped. The Insolvency Service reported 1,036 director disqualifications in 2024–25, with 736 linked to Covid loan abuse. Separately, an ad hoc publication from the Department for Business and Trade and the Insolvency Service identified 114,752 Bounce Back Loans associated with companies that have since been dissolved or entered liquidation. These datasets now frame the debate about effectiveness and fairness in the post-pandemic regime.

Ministers have also reallocated responsibility for parts of Covid-loan fraud work. On 15 May 2025, the Department for Business and Trade confirmed it would end its contract with the National Investigation Service (NATIS) and transfer ongoing casework to the Insolvency Service. The move followed scrutiny of recovery rates and governance, with officials citing the Service’s established enforcement track record as the basis for consolidation.

The enforcement outcomes cited by the Insolvency Service underline where resources have been focused. In the year to March 2025, 1,036 directors were disqualified, averaging eight years per ban, and 131 bankruptcy restrictions were imposed. The agency attributes nearly two-thirds of its disqualification and criminal outcomes to misconduct in Covid-19 financial support schemes, signalling a continued emphasis on pandemic-related wrongdoing.

The ad hoc release on dissolved or liquidated companies shows the scale of facility-level exposure within the insolvency pipeline. Of the 114,752 Bounce Back Loans linked to such companies, 73,977 were in default at the snapshot date, while 38,454 had been fully repaid and 1,779 had their guarantees removed. Officials caution that the data relies on lender submissions to the scheme portal and is not real-time.

NATIS’s closure has been accompanied by further reporting on performance. The Times reported last month that the unit recovered £7.2 million against an estimated £1.9 billion in suspected fraud, despite significant public funding, with remaining investigations moved to the Insolvency Service. While those figures have been contested in the past, the ministerial decision to end the contract and transfer the caseload is on the public record.

The Bounce Back Loan Scheme was deliberately designed to prioritise rapid liquidity, offering lenders a 100% state guarantee while borrowers remained fully liable for their debts. Parliament’s Public Accounts Committee has recorded that lenders were not required to conduct standard credit or affordability checks, relying instead on basic fraud and anti‑money laundering controls. That policy choice reduced lender risk but left taxpayers exposed to higher losses if borrowers failed.

Performance data now published quarterly shows how that risk is crystallising. As at 30 June 2025, businesses had drawn £46.48 billion under BBLS, and lenders had flagged £1.88 billion as suspected fraud. On the same date, the government guarantee had been removed from 13,694 BBLS loans, mainly due to lender discussions and data corrections, underscoring ongoing remediation of earlier records.

Understanding who does what in insolvency remains key for accountability. Official Receivers administer compulsory liquidations and may act as liquidator until a licensed insolvency practitioner is appointed, with fees and deposits set by statutory instruments. Updates coming into force on 9 January 2025 increased certain Official Receiver fees and hourly rates, reflecting the cost of administering complex public interest cases.

The Insolvency Service has set out a new Investigations and Enforcement Strategy for 2026–2031. Published on 16 July 2025, it signals a wider corporate enforcement remit alongside the traditional focus on insolvency misconduct, with plans to increase prosecutions, use proceeds‑of‑crime tools and work more closely with Companies House under the Economic Crime and Corporate Transparency Act 2023.

Recent casework shows how “insolvency avoidance” models are being targeted. On 22 October 2025, two sisters accepted seven‑year bans after enabling a scheme that moved control of 138 struggling companies without proper scrutiny of assets, exposing creditors to losses. The case followed court action to wind up associated entities and sits within the Service’s stated priority to disrupt phoenixism and abuse of corporate structures.

For directors and SMEs, the practical message is straightforward. Keep complete records, expect checks on use of Covid finance, and note that borrowers remain liable even where lenders have claimed on the guarantee. Separately, Companies House will begin mandatory identity verification for directors and people with significant control from 18 November 2025, with a 12‑month transition; acting as a director without verifying will become an offence.

For lenders and advisers, data quality and recovery protocols remain under scrutiny. The Information Commissioner upheld a decision not to name banks that lost guarantees on some pandemic loans, but the British Business Bank continues to report on guarantee removals and suspected fraud flags. As the Insolvency Service implements its 2026–31 plan, stakeholders should expect tighter coordination between Companies House, the Service and other agencies on corporate enforcement.