What do you think has been the biggest change in Regulation & Conduct over the last 10 years?
I think the biggest change is our shift in focus from spending most of our time taking regulatory or disciplinary action against members and firms who had committed misconduct or breached regulations, to focusing more and more on educating and raising awareness of what we see going wrong and how members and firms can avoid getting into difficulty.
This change of focus has also changed the image of Regulation & Conduct, both within the Institute and externally. When I joined, we were still very much regarded as “those unapproachable people in Milton Keynes who wait for accountants to get things wrong and then take pleasure in sanctioning them”. Now, I believe we’re seen as “the people in Milton Keynes who try their best to help us get things right”.
I was pleased to see that shift manifesting itself in ICAEW’s strategy, Direction 2030, which recognises the two interlinked roles of supporting members and firms but also holding them to high professional standards.
A big contributory element to our greater connectivity with ICAEW firms and members is due to our communications work, with the expansion of that team over the last 10 years from 0.5 to 4 FTE. You can have the best ideas in the world, but unless you can communicate them clearly and engagingly through the right channels, they won’t have the impact they should.
What do you see as your personal contribution to this change in image?
I guess it would have to be the four drama films I’ve created over the past 10 years which, I hope, have contributed to improving audit quality and raising awareness of the importance of knowing your client by creating an alternative, more enjoyable way of learning. But the success has been a real team effort within Regulation & Conduct, from the technical specialists who have spent hours correcting my scripts through to the work of the Communications team in promoting the films.
The success of the films has inspired other initiatives within Regulation & Conduct, instigating more effective ways of communicating important information and guidance to members and firms. This can be seen in our trailblazing video series, our interactive live webinars, and the publication of reports from our monitoring visits to name but a few of our educational resources.
What have been the key challenges over the past 10 years?
The biggest challenge has been trying to dispel the widely-perpetuated myth that a professional membership body cannot be relied on to make impartial decisions about the conduct and competence of its members and firms. I know from watching how judgements are made by our regulatory and disciplinary committees that this viewpoint is completely wrong.
All significant decisions are made by independent committees with lay member parity or majority, whose members are appointed by an independent appointment panel. The chartered accountants who serve on them to provide necessary technical insight are as robust, if not more robust, than their lay member colleagues because they care about the profession and the reputation of the Institute, and take very badly when the actions of another member threaten to undermine that reputation.
How has that myth impacted Regulation & Conduct?
It means we’ve had to fight hard over the last 10 years just to convince the Government and oversight regulators that we should continue to be authorised to regulate the services provided by our members and firms.
There have been a number of consultations launched with proposals to remove or reduce our regulatory remit, and we’ve had to spend time explaining why not only we can be relied on, but actually we’re the best placed to regulate because of our in-depth knowledge of our members and firms. It was really disappointing that this wasn’t recognised by HM Treasury when they decided in late 2025 to transfer responsibility for AML supervision away from us and other professional bodies.
However, I’m pleased that we’ve retained our important role in regulating audit work for non-PIE companies and also retained our role as an insolvency regulator in the face of proposals in 2022 to create an independence insolvency regulator. It was also good to see more recently the faith which has been placed in us by the Ministry of Housing, Communities and Local Government (MHCLG) in asking us to take over as the front-line regulator of all local audit, subject to the supervision of the new Local Audit Office.
How has the department changed in terms of its people, organisation and activities?
We’ve seen a 50% increase in staff numbers over the last 10 years. This growth reflects our wider regulatory remit, the increasing demands of our oversight regulators and the success of our third-party assurance work. During this time, we’ve really focused on nurturing, developing and upskilling our own talent, as well as promoting from within wherever possible.
The biggest organisational change was the creation of our Regulatory Practice team, bringing together in one team everyone who plays a role in licensing firms and individuals and supporting the regulatory committees. It seems strange now to think that all those staff numbers were not always in the same team. We’ve also spun out of that team a much smaller but fully focused Regulatory Policy team which has become very proactive in trying to influence changes being considered by Government departments and oversight regulators. That team’s work with MHCLG in helping to shape the new local audit framework is a great example.
As for change in activities, I would say the move from exclusively retrospective monitoring to prospective monitoring within our Quality Assurance Department (QAD) is one of the more significant changes. The creation of the audit risk team within QAD alongside changes in the Audit Regulations is allowing us to identify when audit firms are taking on new, larger audit mandates and allowing us to ask questions of them before they start work to satisfy ourselves that they have the right expertise and resources to perform that audit to a high standard.
The last decade has also seen significant growth in the third-party work carried out by the QAD reviewers, not just in revenue but in the breadth and location of our contracts. While the additional revenue is welcome as it helps make us more self-sufficient, the real benefit of this work is the way in which it broadens the skillsets of our reviewers, and the variety and international location of some of the work also helps with our ability to recruit the very best people.
And you’ve also made major changes to the ICAEW Disciplinary Scheme…
I can still remember the Regulation & Conduct Board meeting in 2019 when, after I’d finished proposing yet another set of Disciplinary bye-law (DBL) changes to deal with another emerging issue, the Chair suggested that I should just re-draft the entire scheme and the speed at which I agreed with that suggestion. I regretted accepting that challenge so quickly on so many occasions during the next 2 years while trying to work out with a small team how to reduce 49 DBLs to 16, how to shape the new Investigation & Disciplinary regulations (IDRs) and how many other sets of regulations would need to be amended due to their links to the existing DBLs. But we got there in the end with the launch of the new framework in June 2023, and some staff may already be wondering how we operated without the IDRs prior to then.
What’s been the most significant change in the disciplinary process in terms of impact?
I’d pick two out for impact.
The first is the introduction of our settlement process for disciplinary cases which are referred by the Conduct Committee for a tribunal hearing. Introducing an option for members and firms to make admissions after the Conduct Committee or to agree a suitable sanction for matters already admitted has significantly reduced the number of tribunal and appeal hearings and resulted in quicker conclusions to difficult cases.
The second would be the introduction of our Fitness Regulations and the Fitness Committee. It seems bizarre now looking back that we had no process in place to respond to disciplinary complaints which arose out of members suffering from mental health issues. All we could do under the old DBLs was to put allegations of misconduct before the disciplinary committees. The alternative regime we introduced encourages staff and committee chairs to raise with me any concerns they have about the mental (or physical) health of any member facing a disciplinary complaint which can result in us paying for a medical assessment and, if our concerns are confirmed, diverting the matter to the Fitness Committee. That committee will then ensure that the right measures are put in place to safeguard the public and allow time for the member’s recovery where possible) while pausing the disciplinary proceedings.
What are your priorities at the moment?
We’re spending a lot of time making improvements which will allow us to deal with a significant surge in the number of new complaints we’re receiving. We believe this increase is being driven by the use of AI and the volume of work generated by those AI tools. This has involved looking at our whole complaint-handling process to see what efficiency changes we can make and looking at putting in some guidelines on what complaints will be accepted as suitable for assessment and investigation.
We’re also taking a long, hard look at the eligibility criteria for the use of the description “Chartered Accountants” and whether we can reduce complexity around our affiliate requirements, as well as re-imagining what the Practice Assurance (PA) scheme could look like when AML compliance is no longer part of a PA visit after 2028.
And, of course, how could I forget? We’re about to start work on ‘Film 5’!
What are your hopes and ambitions for the next decade?
Well, I certainly won’t be here in 10 years so my priority before I retire is to make sure that Regulation & Conduct is prepared and ready to deal with all of the challenges which will inevitably come its way, whether that’s increases in demand for our services or more attempts to reduce our regulatory remit, or something completely new. It’s been a priority for me over the past few years to create a really strong management team to continue our good work into the future.
Do you have any standout personal memories over the past 10 years?
I think there are three standout moments.
The first is the day we received the High Court judgment in the case where our regulatory intervention into the administration of the Comet Group was upheld and lauded by the Judge despite allegations that we had overstepped the mark. Anyone reading that judgment would realise immediately why I get so frustrated at the myth that regulation by your professional body cannot be robust regulation.
The second standout moment was joining a call in September 2023 to tell our dedicated insolvency team that I had just been informed that the Minister had abandoned plans to create an independent insolvency regulator and was satisfied, in light of our representations, that ICAEW and the other Recognised Professional Bodies could be relied on to continue to regulate insolvency. I had promised the team when the proposals first emerged in 2022 that we would fight hard to prove we could be trusted to carry on with our role. Despite the shadow cast over their future, nearly all had stayed with us. So, it was great to see a screen full of happy faces and to have earned the trust the staff put in us.
My third special memory has to be the amazing reception we received for Crossing the Line in Chartered Accountants Hall in May 2025. Hearing the spontaneous, loud applause when the credits rolled at the end of Part 4 from a packed hall made worthwhile all of the sacrifices made during the writing and production process. And it’s that memory which is now inspiring me to make those sacrifices all over again…