In October 2010, allegations of malpractice and weak accountability in UK insolvency featured prominently, with investigator Stephen Hunt citing hundreds of cases and describing fabricated time entries used to inflate fees. The Office of Fair Trading (OFT) also reported low confidence among unsecured creditors and called for reform. Fifteen years on, this follow-up assesses what has - and has not - materially shifted.
The regulatory architecture now includes statutory objectives for the professional bodies that license insolvency practitioners and new state powers to intervene. Through the Small Business, Enterprise and Employment Act 2015, ministers gained tools to direct or reprimand Recognised Professional Bodies (RPBs) and, where it is in the public interest, to ask the courts for a direct sanctions order against an individual practitioner. These measures sit alongside the Insolvency Service’s role as oversight regulator.
Complaint handling has become more centralised. Since June 2013, the Insolvency Practitioner Complaints Gateway has acted as a single entry point run by the Insolvency Service, replacing fragmented routes into different RPBs. In 2024, the Gateway recorded 656 complaints; 144 (22%) were referred to RPBs, with the remainder rejected, closed or awaiting information at year-end. First-year data in 2013–14 showed 900+ complaints as the system bedded in.
There is also clearer disclosure of enforcement. According to the Insolvency Service’s 2024 Annual Review, RPBs reported 63 published disciplinary or regulatory sanctions across the year (ICAEW 16; IPA 46; ICAS 1). Licence restrictions, exclusions and further investigations were also recorded. These are not headline-grabbing numbers in a profession of around 1,500 authorised individuals, but they demonstrate regular use of disciplinary tools under a more transparent framework.
On corporate rescues and sales to insiders, the rules are tighter. Since 30 April 2021, an administrator cannot complete a substantial disposal to a connected person in the first eight weeks without creditor approval or an independent evaluator’s report. In 2024, RPB monitoring indicated evaluators’ opinions were obtained in virtually all connected-person pre-packs reviewed. This replaced earlier voluntary approaches and was designed to reduce perceived undervaluations in quick sales.
Creditors’ involvement and remuneration controls have been reworked. The Insolvency (England and Wales) Rules 2016 replaced most physical meetings with decision procedures (including deemed consent for many matters) and built a fee-estimate regime that caps drawings without further approval. Time-recording and disclosure duties around costs are now more explicit. These changes were intended to streamline process while preserving creditor consent on fees.
Professional standards have been tightened through Statements of Insolvency Practice. A 2021 overhaul of SIP 9 expanded principles on payments to office-holders and associates, requiring enhanced disclosure and approval where independence might be perceived to be at risk. Guidance from RPBs and trade sources emphasises fair, reasonable and proportionate costs with clearer reporting to creditors. A revised Insolvency Code of Ethics then took effect on 1 October 2025.
Financial safeguards have been strengthened. From 1 December 2024 the general penalty sum on insolvency bonds rose from £250,000 to £750,000, with minimum run‑off cover and clearer indemnity periods, and bonds must now cover certain successor practitioner costs and interest from loss to payment. These reforms aim to leave more headroom for creditor recovery in proven fraud or dishonesty cases.
The government consulted in December 2021 on a wholesale shift to a single regulator and statutory firm regulation. In its 12 September 2023 response, ministers confirmed they would not create a single regulator “at this stage”, but would legislate for regulation of firms offering insolvency services, a mandatory public register covering individuals and firms, and government‑set professional and ethical standards. Delivery awaits Parliamentary time.
The map of regulators has narrowed. Chartered Accountants Ireland applied to leave the regime and, via the Insolvency Practitioners (Recognised Professional Bodies) (Revocation of Recognition of the Institute of Chartered Accountants in Ireland) Order 2025, ceased to be an RPB from 1 June 2025. Practitioners transferred to other RPBs, leaving three UK bodies - ICAEW, ICAS and the IPA - operating under Insolvency Service oversight.
For unsecured creditors, returns remain challenging. Recent government‑commissioned research into creditors’ voluntary liquidations found recoveries below £10,000 in most cases reviewed and none at all in a material minority, reflecting low‑asset estates. The 2020 restoration of HMRC’s secondary preferential status also moved certain tax debts ahead of floating charge holders and ordinary unsecured creditors, further compressing residual distributions.
So what has really changed? Oversight is measurably stronger: there is a single complaints gateway, more explicit fee controls, mandatory scrutiny of connected‑party pre‑packs, upgraded bonding, and a refreshed ethics code. What has not changed is the basic model of profession‑led regulation, pending legislation for firm‑level authorisation and a public register. For creditors and directors, the practical takeaway is to use the Gateway where warranted, scrutinise fee estimates and evaluator reports, and watch for forthcoming firm‑regulation and register legislation that could alter accountability again.