Consultation responses: Proposed revisions to ICAEW Disciplinary Sanctions Guidance

About the consultation

The consultation ran between April and June 2025 and sought views on the clarity, proportionality and structure of the revised disciplinary sanctions. It also asked for feedback on the alignment of the guidance with ICAEW’s wider regulatory strategy and the expectations of members, firms, committees and external stakeholders.

Consultation responses

ICAEW received 40 formal written responses, including submissions from member firms, individual members, disciplinary committee members, and members of the public. Informal feedback was also provided through meetings and correspondence during the consultation period.

Overall, respondents were supportive of the objectives and direction of the revised guidance, with a number of constructive suggestions to support clarity, usability and transparency. Key themes included:

• the importance of clarity around the full range of sanctions,
• proportionality and consistency in financial penalties,
• the treatment of dishonesty, sexual misconduct and non-cooperation,
• distinctions between sanctions for firms and individuals,
• requests for clarification in breach-specific sections such as tax, audit and PII,
• and calls for supporting materials, such as examples or training, to promote consistency.

Changes implemented following consultation feedback

A number of targeted amendments have been made to the DSG in light of the consultation feedback. These include clearer wording on available sanctions, reinstatement of time-to-pay guidance, enhanced PII wording, clarification of breach-specific factors, amendments relating to provisional members, and the inclusion of the 30% admission discount within the visual flowchart. Other areas, such as dishonesty, non-cooperation and sexual misconduct, did not prompt further amendments but have resulted in clarifications of ICAEW’s policy position or the development of separate supporting guidance.

Full list of consultation responses and ICAEW comments

• View a full table of the consultation comments and ICAEW’s responses

ICAEW would like to thank all respondents for their detailed and thoughtful feedback. Their contributions have played an important role in refining and strengthening the 2026 Disciplinary Sanctions Guidance, ensuring it remains clear, proportionate and aligned with ICAEW’s regulatory objectives.

Next steps

ICAEW Disciplinary Sanctions Guidance will apply top 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 Guidance on Sanctions until conclusion.

ICAEW’s regulatory committees will also continue to refer to the Guidance on Sanctions document regarding regulatory penalties, until a review of regulatory sanctions has been completed, consulted on and finalised during 2026.

Further information

• ICAEW Guidance on Sanctions and fixed penalty process
• About ICAEW's disciplinary committees