IPA statement: Response to the Insolvency Service 2025 Annual Review of Insolvency Practitioner Regulation
9 July 2026
On 7 July 2026, the Insolvency Service published its Annual Review of Insolvency Practitioner Regulation for 2025 together with its supporting statistical information.
The report can be found here.
Introduction
As recognised by organisations such as the Institute of Regulation, effective, robust regulation protects the public and enables businesses to thrive on a level playing field. In the context of the insolvency profession, this means ensuring that debtors are treated fairly, creditors receive an equitable return, and that Insolvency Practitioners (IPs) and their firms compete fairly while complying with clear standards that are applied consistently and proportionately.
However, this year’s review by the Insolvency Service also highlights that insolvency regulation in the UK remains fragmented. While the number of Recognised Professional Bodies (RPBs) overseen by the Insolvency Service regulating IPs has reduced from eight to three, we continue to believe that three is too many. Effective regulation requires consistency. The more insolvency regulators there are, the greater the risk that debtors, creditors and IPs themselves are subject to different regulatory approaches depending on who oversees them.
The Insolvency Service seeks to promote greater consistency partly by publishing data on insolvency regulation, and we welcome this report as an important contribution to transparency and understanding across the profession. However, we remain concerned that inconsistencies in the underlying data limit the report’s ability to provide meaningful comparisons between the RPBs.
The structural and operational differences between the RPBs can make it harder to compare like with like. Without sufficient context, the data may be misinterpreted, leading to inaccurate conclusions and, ultimately, less effective policymaking.
It is therefore encouraging that the Insolvency Service has recognised these challenges. The report explains that the 2025 data has informed its regulatory priorities for 2026, including a commitment to developing a better understanding of the different regulatory approaches adopted by the RPBs. We welcome this commitment and hope it will lead to more consistent reporting and more meaningful comparisons in future. We set out our specific observations on the report below.
Overview of regulatory developments
The report details several policy, legislative, and system developments that impacted the profession in 2025, which included:
Standard-Setting Transition
In late 2025, the Insolvency Service started to transition formal responsibility for setting ethical and professional standards away from the Joint Insolvency Committee (JIC) directly to themselves, reporting to the Secretary of State. The IPA is actively engaged in this scoping process to ensure good continuity to benefit the profession.
Ethical and Professional Updates
The report highlights the implementation of the updated Insolvency Guidance Paper on complaint handling and the revised Code of Ethics, both of which came into effect on 1 October 2025. Reviews of SIP 2, SIP 3.1, and SIP 14 also progressed throughout 2025.
The IVA Market
Improving the Individual Voluntary Arrangement (IVA) market remained a core focus, also set out in the report. The implementation of the revised IVA Protocol 2025 on 1 April 2025 introduced tighter controls, including the mandatory ‘Key Facts’ document and clearer rules around suitability and home ownership.
Bonding Regime and Corporate Transparency
The report also notes the implementation of tougher statutory bonding requirements, which became mandatory for all new bonds on 1 January 2026. It also notes the ongoing rollout of Companies House identity verification reforms under the Economic Crime and Corporate Transparency Act 2023.
System Transformations
The Insolvency Service highlighted its delayed launch of its new case management and estate accounting system, INSSight, as well as the transition of the Official Receivers’ rota from a local to a regional system in Autumn 2025.
Statistical information
The supporting statistical information highlights volume shifts across the profession, most notably a 47% increase in new cases handled by the Complaints Gateway, which rose from 656 cases in 2024 to 966 in 2025. Of the cases referred to RPBs, IVAs accounted for the largest share (45%), followed by liquidations (30%). Communication-related issues remained the primary driver of complaints, representing 37% of all referrals.
The report does not seek to explain the increase in overall complaint volumes. However, one possible contributing factor is the growing availability of consumer artificial intelligence (AI) tools. The ability to generate detailed correspondence quickly and with minimal effort may be increasing the volume of complaints about IPs. This inevitably places additional demands on firms, particularly where teams are managing high case volumes. As response times come under pressure, communication issues are more likely to arise, a trend reflected in the complaints data. The IPA recognises these challenges and continues to support IPs and their firms to maintain effective communication and high standard of service.
Following the growth reported in the 2024 review, the size of the profession has since remained broadly stable. The total number of IPs authorised in the UK at the start of 2026 was 1,480, compared with 1,504 in 2025. The IPA continues to regulate a significant proportion of the profession, with 637 authorised IPs, including 554 appointment takers.
The publication of these statistics aims to improve transparency across the profession. However, it also highlights the limitations of comparing data across a fragmented regulatory framework. Each RPB operates its own supervisory approach and regulatory model, meaning that headline figures do not always provide a like-for-like comparison.
For example, it is inevitable that RPBs will adopt different approaches to assessing and managing risk. The IPA publishes its risk assessment models, including those used for our unique Volume Provider Regulation (VPR) Scheme, which is the market-leading regulatory scheme for the UK’s personal insolvency providers. However, there is no equivalent transparency of how other RPBs assess risk, meaning that direct comparisons of risk-related data are not reliable.
A further example can be found in Table 3 (Outcomes considered by RPB Committees) of the report, where the ICAEW is recorded as issuing 13 “Regulatory Orders” and making 10 “referrals to complaints department”, while the IPA records zero in both categories. This does not indicate a lower level of regulatory oversight. Rather, it reflects differences in regulatory frameworks and terminology. For example, some RPBs utilise financial “Regulatory Penalties” which can only be issued during monitoring visits. The IPA does not use this approach, instead relying instead on a robust committee-led disciplinary process that results in parallel, albeit differently named, regulatory outcomes. These differences make direct cross-sector comparison difficult, and can hinder understanding for creditors, debtors and other stakeholders.
By publishing these figures side-by-side without explaining the differing regulatory frameworks, thresholds and disciplinary regimes, the Insolvency Service risks leading readers to draw inaccurate conclusions. We are therefore pleased that the Insolvency Service has recognised this as an area for improvement, with the incoming Chief Executive identifying the enhancement of insolvency regulation a priority for the coming year. We welcome this approach, which should help the Insolvency Service and its stakeholders better understand the differing approaches to risk assessment, complaints handling and disciplinary outcomes across individual RPBs.
Looking forward
The UK Government has long advocated for a single insolvency regulator, an aspiration that the IPA has consistently and unequivocally supported. While the legislative changes required to achieve this mean that a single insolvency regulator is unlikely to be realised in the near term, the current fragmented data landscape demonstrates why reform is needed.
The IPA is the only UK-wide regulator dedicated exclusively to maintaining high standards in insolvency practice. We believe that consolidating insolvency regulation under a single regulatory framework will improve consistency, transparency, and regulatory effectiveness, and also deliver meaningful cost savings for firms and the taxpayer. Reducing unnecessary duplications would allow more funds to be returned to creditors and redirected into productive economic activity, supporting growth across the UK economy.
In the meantime, the IPA will continue to work proactively with the Insolvency Service and the other RPBs to improve consistency, align our frameworks where appropriate, and promote greater transparency in risk assessment, complaints handling and disciplinary outcomes. Greater consistency in these areas will enable more meaningful comparisons across the sector and strengthen confidence in the insolvency regulatory regime.