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Consultation: Proposed revisions to ICAEW Sanctions Guidance

Published: 23 Apr 2025 Update History

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ICAEW is consulting on new Disciplinary Sanctions Guidance. The guidance outlines how sanctions will be determined in disciplinary cases involving ICAEW-regulated firms and individuals. This guidance is used by ICAEW’s Conduct Committee, Tribunals Committee and Appeal Committee when considering disciplinary allegations.

The proposed changes follow a comprehensive review of the current ICAEW Guidance on Sanctions and aim to ensure it reflects evolving regulatory expectations, supports public confidence, and remains proportionate, transparent and fair in its application.

The consultation period will run from 23 April to 9 June 2025.

Background

ICAEW’s Guidance on Sanctions plays a critical role in supporting consistent decision-making across disciplinary cases. It provides:

  • A framework for assessing the seriousness of misconduct
  • Guidance on appropriate sanctions
  • Transparency for those subject to the disciplinary process

The proposed changes are the result of extensive engagement with disciplinary committee members and ICAEW staff, as well as a comparative review of similar guidance issued by other professional and regulatory bodies.

Following this review, the ICAEW Regulatory Board approved a plan to split the existing Guidance on Sanctions into two separate documents:

  1. Disciplinary Sanctions Guidance – for use by ICAEW's disciplinary committees (the topic of this consultation)
  2. Regulatory Sanctions Guidance – for use by ICAEW's regulatory committees (this document will be consulted on separately in late 2025/early 2026).

Purpose of the consultation

The ICAEW Regulatory Board (IRB) is seeking views on proposed revisions that aim to:

  • Improve the clarity, consistency and usability of the guidance for decision-makers and those subject to disciplinary proceedings.
  • Ensure sanctions are proportionate to the seriousness of the misconduct.
  • Promote transparency and fairness in outcomes.
  • Reinforce ICAEW’s commitment to acting in the public interest.

This consultation will be of interest to regulated individuals and firms, their clients, oversight regulators, professional bodies, legal representatives, and other members of the public. Feedback from all stakeholders is welcome.

Key proposals

The proposed Disciplinary Sanctions Guidance introduces the following changes:

  • revised overarching guidelines with updated amounts for financial penalties in line with inflation;
  • the introduction of a section to deal with dishonesty;
  • definitions of seriousness (very serious, serious, less serious) which better reflect the nature of the misconduct;
  • new or updated sections on ethical breaches, sexual misconduct, audit-related misconduct, non-cooperation, anti-money laundering compliance, and tax-related breaches;
  • updated common and breach-specific aggravating/mitigating factors;
  • inclusion of distinct guidance for firms and individuals where relevant;
  • increased penalties for ethical breaches and for failing to co-operate with ICAEW investigations or conduct which frustrates ICAEW’s regulatory functions;
  • categories and language aligned to ICAEW’s Code of Ethics and citing a specific breach where relevant to bring greater clarity; and
  • an updated audit section with revised audit fee multipliers and guidance that financial turnover is considered when considering a proportionate sanction where appropriate.

The aim is to strengthen the structure and accessibility of the guidance and provide disciplinary committees with a more robust and practical tool for decision-making.

Impact and inclusion

ICAEW does not believe that the proposed changes will result in worse outcomes or quality of service for individuals or firms with protected characteristics. However, it welcomes views on any potential unintended impacts from an equality, diversity and inclusion (EDI) perspective.

Have your say

We encourage responses from all interested parties. Your feedback will help ensure that the final version of the guidance is clear, proportionate, and meets the expectations of stakeholders and the public.

Submit your response by 9 June 2025 via email to: sanctionsconsultation@icaew.com

Or post your response to:
Regulatory & Conduct Director
Professional Standards Department
ICAEW
Metropolitan House
Avebury Boulevard
Milton Keynes
MK9 3FZ

If you require any adjustments to enable you to respond (eg, for accessibility reasons), please get in touch.

Have your say

Read and respond to the full consultation document.

Download the consultationRead the proposed Disciplinary Sanctions Guidance