Insolvency Practitioner guidance on the Covid repayment window

2 October 2025

You may be aware that HM Treasury announced a new voluntary repayment scheme on 12 September 2025 aimed at helping recover public money lost during the pandemic. The scheme gives individuals and businesses who wrongly claimed COVID support funds until 25 December 2025 to return pandemic scheme money before tougher sanctions apply. The announcement and links to the repayment scheme can be found here.

The IPA has been in correspondence with the Insolvency Service about any impact the announcement from the Covid Counter-Fraud Commissioner will have on Insolvency Practitioners’ duties. The Insolvency Service has confirmed that repayment under the voluntary repayment scheme does not guarantee any protection to directors from enforcement action and that Insolvency Practitioners should continue to report misconduct in the usual way through the director conduct reporting service, including whether they are aware of any repayment being made.

Where an Insolvency Practitioner becomes aware of a possible fraud outside of an insolvency situation, they should report it to the appropriate authorities.

The IPA is working to ensure that the Government’s FAQs accompanying the announcement reflect insolvency situations and specifically that they state that directors seeking to make a repayment in an insolvency situation should contact either the Insolvency Practitioner or Official Receiver appointed, rather than repaying direct to lenders.

Members are asked to contact us with any practical difficulties, should they arise, and we will raise such issues with the Insolvency Service.