Proposed changes to Statement of Insolvency Practice 2

SIP 2 was last updated in 2016. The proposed changes are outlined in the explainer notes below.

The introduction of specific reference to a requirement for Analysis

The headline suggested amendment to the SIP is to include Analysis within the title and, where seen relevant to do so, within the body of the SIP.

The Working Group’s (WG’s) intention here was to ensure that it was explicit, when deemed necessary (ie, when proportionate, economic etc) that the SIP required an interrogation of information/data (analysis) rather than instead a gathering in, and non-interrogation, of that data.

The WG’s intent is for the inclusion of analysis within the SIP to be introduced in a non-specific/non-instructive manner. This approach has been favoured here both to ensure that the SIP is not quickly outdated in the face of the continuing developments in investigative and analytical tools available to the sector (AI, etc) and also to ensure that the analysis requirements remain ones which are ultimately dependent on the specifics of the individual cases (proportionality, economic viability etc).

A more specific emphasis on reporting requirements to regulators

The SIP has sought to make clear that certain reporting requirements can both continue after statutory specific timings (as at paragraph 4d) and can see a requirement for reports to be filed to multiple regulators (as at paragraph 29).

Updates to reflect changes since the SIP was last updated

The WG has sought to update the SIP to ensure that it is accurate at this current time. That has primarily seen updates to the names of regulators but has also seen the addition of practices more common in the sector since the SIP was last updated including the addition, jurisdiction dependent, of a consideration of an assignment of claim (paragraph 15).

The SIP has also been amended to be easier to read and to flow more naturally between relevant and connected points within the SIP.

Continued use of “books and records (in whatever form)”

The WG has not sought to amend the wording, or to provide an explanatory note for what is meant by the continued use of the wording, “books and records (in whatever form)”. The WG believes that the continuing use of “in whatever form” is sufficient to convey that whatever the nature of a company’s records (be they paper based, digital, messaging apps etc) they will be covered by this SIP. The WG feels that to be more specific would open the SIP to quickly becoming outdated.

You can see the full details of the proposed changes below:

• View the proposed revised SIP: Consultation Draft 2026
• View a comparison with the version of the SIP currently in force

• Access the consultation questions via our digital survey form

If you are unable to access the digital survey form, please post your response. The address to use is:

1. Do you think the revised SIP identifies all relevant principles and key compliance standards?
2. Is adding analysis to the SIP’s title and content a useful improvement to the Standard, and does the SIP clearly reflect the intended purpose described above, or is further specificity needed?
3. Does the continued reference to “books and records (in whatever form)” within SIP 2 adequately encompass the full range of a company’s records, including wider operational and business information such as electronic communications (including emails and messaging applications), contractual documentation, and other non-financial records?
   
   If you believe that it does not continue to be the appropriate wording, please confirm:
   
   (i) the reasoning behind your having reached that conclusion; and
   (ii) your thoughts on a more adequate wording to cover the full range of a company's records.
4. Does the proposed amended SIP sufficiently address any concerns held relating to the key areas of the SIP including investigation, analysis and reporting?

If you feel that there are areas that could be strengthened or added, or alternatively that are surplus to requirements, please expand upon that thinking in your reply.

The consultation is open until 6 August 2026.

The WG welcomes your consultation responses. When the consultation closes, it will consider all the feedback. There is no intention to amend the SIP without careful consideration of the responses received and any plan to introduce changes will take into account any continuing challenges faced by the insolvency profession. More information will be published once any proposed changes are finalised including any amendments that have been made as a result of your comments.

The proposed revised SIP 2 will apply in England and Wales, Scotland and Northern Ireland and will replace the individual SIP 2s which apply in each jurisdiction.