Consultation on changes to Statement of Insolvency Practice 2 – call for responses
14 May 2026
Statement of Insolvency Practice 2 – Investigations by Office Holders in administrations and insolvent liquidations and the submission of conduct reports by Office Holders (SIP 2)
The Joint Insolvency Committee, of which the IPA is a member, is consulting on changes to SIP 2.
Introduction of ‘Analysis’
The headline amendment to SIP2 is the introduction of specific reference to a requirement for ‘Analysis’ within in the title and the body of the SIP. The intention behind the introduction was to ensure that it was explicit, when deemed necessary (i.e., when proportionate, economic etc.) that the SIP required an interrogation of information/data (analysis) rather than a gathering in, and non-interrogation, of that data.
Furthermore, the inclusion of “Analysis” within the SIP is 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 This approach has been favoured here, both to ensure that the SIP is not quickly outdated in the face of the continuing developments in investigative and analytical tools available to the sector (AI etc.)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 to ensure that the analysis requirements remain ones which are ultimately dependent on the specifics of the individual cases (proportionality, economic viability etc.).
Specific emphasis on reporting requirements to regulators
The SIP has sought to make clear that certain reporting requirements can continue after statutory specific timings (as at paragraph 4d) and involve reports being filed with multiple regulators (as at paragraph 29).
Updates to reflect changes since the SIP was last updated in 2016
The SIP has been updated to ensure that it is accurate at this current time. That has primarily seen updates to the names of regulators as well as the addition of practices more common in the sector since the SIP was last updated including the addition, of a consideration of an assignment/assignation 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 Working Group (‘WG’) established to review the SIP 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.
Consultation documents
(1) Proposed revised SIP 2 (Clean)
(2) Proposed revised SIP 2 (Tracked)
Important dates
The consultation will be open for a period of 12 weeks.
Consultation commencement date: 14 May 2026
Consultation closing date: 6 August 2026
Your views
To help shape our response to the Consultation, we kindly ask you to provide your answers to the consultation questions by clicking below.
If you are unable to access the online questions, please feel free to provide your answers/feedback to the consultation to Ben Luxford, Technical Lead at benl@ipa.uk.com.
Consultation questions
1. Do you think the revised SIP 2 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 the 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 2 sufficiently address any concerns held relating to the key areas of the SIP including investigation, analysis and reporting?
Background
SIP 2 was last updated in 2016. Since then, investigations by office holders have continued to be a key focus for the Insolvency Service and insolvency recognised professional bodies as part of the wider insolvency objectives of protecting and promoting the public interest, promoting the maximisation of the value of returns to creditors and generally maintaining trust and confidence in the insolvency regimes.
In addition, there have been developments in technology and ways of working since SIP 2 was last reviewed. It is anticipated that further developments, for example in relation to AI and open banking, will impact the nature of and how investigation work may be carried out by insolvency practitioners.
While the existing SIP 2 is robust, the Joint Insolvency Committee, through a WG, has undertaken a review to ensure that it remains relevant and effective in the current and future landscape. The WG has proposed a revised SIP 2 and the JIC has approved its circulation to the profession and other stakeholders for consultation.