ICAEW is consulting on proposed new Regulatory Committees: Measures and Sanctions Guidance. The proposals replace the relevant regulatory sections of ICAEW’s existing Guidance on Sanctions with four committee-specific documents, providing clearer guidance on regulatory measures, penalties and the factors committees should consider when determining appropriate outcomes.
Regulatory Committees: Measures and Sanctions Guidance consultation
This consultation will run from 5 October to 6 November 2026.
Why are we consulting?
The ICAEW Regulation & Conduct Board is consulting on proposed new Regulatory Committees: Measures and Sanctions Guidance, developed as part of ICAEW’s wider review of its Guidance on Sanctions. The review considered whether the existing guidance remains clear, proportionate and reflective of the regulatory frameworks within which the committees operate.
What are the main proposed changes?
- A move from a single guidance document to separate committee-specific guidance for the Audit Registration Committee, Practice Assurance Committee, Investment Business Committee and Legal Services Committee. The documents will use the terminology, requirements, measures and sanctions relevant to each regulated area.*
- Clearer terminology that reflects the relevant regulations and regulatory requirements for each area.
- A clearer distinction between regulatory measures, such as conditions, restrictions, undertakings, suspension or withdrawal, and regulatory penalties imposed in response to a breach.
- Updated indicative sanctions tables, including clearer starting points for relevant regulatory breaches.
- A consistent approach to assessing seriousness using the very serious, serious and less serious framework adopted through ICAEW’s wider sanctions review.
- Clearer aggravating and mitigating factors to help committees decide whether movement from an indicative starting point is appropriate.
- Additional committee-specific guidance where needed to reflect the relevant regulatory context, powers and risks.
We welcome views on the proposed changes, including any gaps, practical difficulties or unintended consequences to consider before finalising the guidance.
Respondents may comment on any or all of the four guidance documents. Please make clear if your response relates to a specific committee, regulated area or regulatory breach.
*The Insolvency Licensing Committee is excluded because insolvency practitioners are subject to the Insolvency Common Sanctions Guidance, agreed with the Insolvency Service and applied across the recognised professional bodies.
Complete consultation and supporting documents
View the four committee-specific guidance documents covering the committees referenced in the complete consultation document.
- Proposed Audit Registration Committee Measures and Sanctions Guidance
- Proposed Practice Assurance Committee Measures and Sanctions Guidance
- Proposed Investment Business Committee Measures and Sanctions Guidance
- Proposed Legal Services Committee Measures and Sanctions Guidance
Equality, diversity and inclusion
We do not believe the proposed changes will result in a worse outcome or quality of service for anyone due to their background or life circumstances. In the questions included with the consultation, please tell us if you think your firm or any of your clients will be adversely impacted by the proposals due to a protected characteristic (such as age, disability or race).
How to respond
Please respond using the online form or by post. You may answer all the questions or only those relevant to you.
Or post your responses to:
FAO Adjudication team
ICAEW Regulation & Conduct
Metropolitan House
321 Avebury Boulevard
Milton Keynes MK9 3FZ
Please contact us if you need anything further, for example for accessibility reasons, to enable you to submit your response.
Timeline and next steps
The consultation is open from 5 October to 6 November 2026.
After the consultation closes, we will consider all feedback received, discuss the results with the ICAEW Regulation & Conduct Board and relevant stakeholders, and make any resulting changes as appropriate. ICAEW will then publish a summary of the results alongside its responses to the feedback and final changes.