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Guidance on Sanctions and fixed penalty process

The documents included on this web page set out the key decisions in the sanctions process and the approach ICAEW committees must take whenever they make a sanctions order against a member, firm, affiliate or provisional member.

The Guidance on Sanctions (GOS) is currently used by the Conduct Committee, Tribunals Committee, Appeal Committee, and the regulatory committees for all disciplinary allegations and regulatory penalty matters considered against ICAEW members (current and former), students, affiliates, and member, regulated and contracted firms.

Guidance on Sanctions

From 1 January 2026 a new Disciplinary Sanctions Guidance (DSG) will come into effect. It will apply to all matters considered by the Conduct Committee for the first time on or after 1 January 2026.

Any matter considered by the Conduct Committee before 1 January 2026 will continue to follow the current GOS until conclusion.

This page outlines the updates and provides access to both the current GOS and forthcoming DSG, and explains when each version applies.

Current Guidance on Sanctions – effective 1 June 2023

This version remains effective for:

  • all disciplinary matters considered by the Conduct Committee before 1 January 2026, which will continue under this guidance until conclusion; and
  • all regulatory committees.

New Disciplinary Sanctions Guidance – effective 1 January 2026

This new version will apply to all disciplinary matters considered by the Conduct Committee for the first time on or after 1 January 2026.

NOTE: The DSG has been approved by ICAEW’s Board and will come into effect on 1 January 2026. Certain aspects relating to legal services regulation remain subject to approval by the Legal Services Board and will be updated if required.

Guidance on Sanctions archive

Fixed penalty process for minor complaints

The fixed penalty process enables certain types of lower level, compliance-type complaints to be dealt with by way of fixed penalty. The process only applies to allegations which the ICAEW Regulatory Board determines suitable for the process and where the allegation(s) and proposed penalty are agreed by respondents/respondent firms. The new process avoids the need for less serious complaints to be considered by the Conduct Committee and therefore matters are dealt with more efficiently.