IPA Technical Insights – April 2026

Welcome to this edition of Technical Insights. We have curated a focused round-up of key messages, legislative reminders and essential updates to support you and your practice to ensure continued compliance in an evolving regulatory landscape.

IPA Regulation

FCA – Motor finance consumer redress scheme

The FCA published their policy statement  PS26/3 on 30 March 2026 (CP25/27: Motor finance consumer redress scheme | FCA ), confirming an industry-wide motor finance redress scheme covering agreements from 6 April 2007 to 1 November 2024.

The IPA submitted a detailed consultation response in November 2025 identifying up to £71m of compensation value within insolvency estates and making six specific recommendations to protect creditor returns.

The FCA has not adopted a formal insolvency protocol within the scheme rules. However, the principle that compensation vests in insolvency estates, not individuals, has been acknowledged through Insolvency Service guidance and RPB interim guidance (Interim Guidance) published ahead of the scheme launch. The IPA’s core concern about correct payment routing has therefore been recognised but unfortunately not mandated into the redress FCA rules.

The scheme launches in two tranches. Lenders have until 30 June 2026 (post-2014 agreements) and 31 August 2026 (pre-2014) to begin engaging with claimants. IVA supervisors should be alert to lenders making contact and should not assume firms will correctly identify the insolvency status without prompting.

Important note – The RPBs are undertaking a review of the Interim Guidance with a view to releasing an updated version following this update by the FCA. In the meantime, the Interim Guidance is still applicable.

Anti-Money Laundering

Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (‘Regulations’)

HM Treasury has laid these draft Regulations in Parliament. This Statutory Instrument (SI) implements the package of reforms set out in the Government’s response to its consultation on  Improving the Effectiveness of the Money Laundering Regulations.

The SI is currently in draft. Subject to parliamentary time, the SI will be approved/made in early June, with the majority of provisions coming into force 21 days thereafter, which is expected to be late June or early July 2026 with the remainder of the provisions coming into force in 2027.

Please read the latest AML Digest (Edition 11) for information about these regulations.

Responses to questions from the IPA Learning March AML webinar

We had a record attendance at our IPA Learning session on 17 March 2026. As a result, we couldn’t deal with every question that was asked on the day, so we promised to get back to you with our responses. These are below.

I was appointed as Liquidator from the OR rota. What are my responsibilities prior to taking the appointment?

This is covered by paragraphs F.3.8 and  F.3.9 in the CCAB Guidance Insolvency Appendix F. Where you are appointed without prior involvement with the insolvent individual or entity, you can place some reliance on the order of appointment and initial Court Order to evidence the identity of the insolvent. However, this does not remove the need to consider the identity of any beneficial ownership or to consider if MLTF activity has taken place (the ‘assess’ part of CDD/EDD) as well as continuing to monitor risks during the appointment.

Please expand on what an IP must to do to verify source of funds in MVL.

As we discussed during the webinar, this should be founded on a risk-based approach. Sense-check the information you hold – do the funds held by the company marry with the turnover and receipts/funds introduced via trade into the company bank accounts? Has the sale of any major asset been undertaken and can this be supported with proper valuations, legal advice and can the sale be evidenced? If it was undertaken by the agents or solicitors, is there other evidence that you can rely on? Fundamentally, can you identify the source of the funds that are to be distributed. As an IP you need to be content that the funds you are going to hold and distribute as Liquidator are ‘legitimate’ – so any checks that you can carry out to provide you with comfort that the details you are seeing do seem to match with the trading pattern, business activity and or asset sale would assist.

A few months ago, Turnkey demo’d a product to deal with ID verification using “One ID”. Does the IPA have a view on whether this is compliant  and acceptable?

As with any electronic ID verification (IDV) system, this is simply a tool that has been devised to assist you with your identification verification requirements. Any tool that you use – OneID, Creditsafe, Veriphy, SmartSearch etc. – is designed to provide you with information on identification and verification of the individuals/entities. This is just one part of customer due diligence (CDD).

None of the IDV systems assess the risks of transacting with the individual or entity which is the required other strand of CDD/EDD work. That is for you to do, using not just the ID information but also all the other information you have regarding the activity and status of the person or the activity and trading history of the business or company. You must bring your personal expertise to the task of risk assessment once IDV has been conducted. Without that assessment, it does not matter what electronic verification system is used, you will not have completed CDD/EDD checks as per the MLR17.

Company is in Creditor Voluntary Liquidation. Liquidator is pursuing a director loan account (DLA) from the director who is now in an IVA . The Supervisor in the IVA is receiving third party funds. What AML checks should the liquidator undertake prior to/upon receipt of the dividend from the IVA?

As we discussed on the webinar – this is for the Supervisor of the IVA to deal with, not you as Liquidator of the CVL. If you are a Supervisor (or in any capacity as office holder) receiving third party funds, you should check F.3.19 of the CCAB Guidance Insolvency Appendix F: CDD on the payer of other funds. If you do have concerns however, you are entitled to raise a SAR and DAML request via your MLRO.

If a full SmartSearch with watchlist search is undertaken as standard on all CDD, what is needed on top of this if a requirement for EDD is identified?

We agree that with the sophistication and the breadth of checks that can be undertaken now, it is almost EDD on every case.

However, separate checks on social media, Google search, LinkedIn etc. can be made to sense check and ensure that you are content that the information is complete.  Also consider third-party validation if appropriate e.g. to confirm that registration is genuine or document is valid.

What due diligence should be taken regarding company customers when realising a debtor balance if the minimum amount is exceeded? It’s hard enough to recover debts let alone verify the customer

CCAB Guidance Insolvency Appendix F has a section on CDD on purchasers of an entity’s assets, paragraphs F.3.15 to F.3.18. Rather than repeat the guidance in detail, a link to the guidance is here. 

CCAB guidance is clear that if there are asset realisations/distributions, this is high risk. Therefore 95%+ cases are high risk. Applying different is against guidance?

Insolvency, particularly MVL appointments, is recognised as a high risk sector for ML activity. Assets realisations and distributions are listed as a potential higher risk indicators in Service Risk factors (per Reg 18). CCAB Guidance Insolvency Appendix F.2.4 states ‘…IPs must take steps to identify all areas of relevant risks, the severity of the threat presented by them and respond appropriately to them.’

A high risk indicator is therefore just an indicator of potential higher risk. You are entitled, as we outlined in the webinar, to consider that the circumstances of a case are such that the case is a normal or low risk in insolvency terms (for example there are no significant assets to realise and trading ceased sometime prior to appointment) or to conclude that it is higher risk (for example the company is trading overseas and has exposure to FATF listed countries), but please ensure that you note the reasons for your conclusions as to level of risk and how you will mitigate that, if possible.

Your risk assessment, starting with an initial ethical code considerations, must be kept under review during the life of an appointment to ensure that any risks remain effectively understood, managed and mitigated. However, if you wish to treat every case as high-risk and undertake EDD on all cases, you are entitled to do so.  

If a case administrator was to submit a SAR, can you confirm if the IP should be made aware.

Firstly, we wonder why a case administrator is submitting a SAR. If a member of staff has a suspicion of potential MLTF they should be reporting their suspicions to the firm’s MLRO. It is then for the MLRO to consider the detail and decide if a SAR should or should not be submitted to the NCA. This process should be clearly set out in any firm’s SAR policy.

On the specific point raised, this would not be tipping-off under S333B (1) POCA 2002. This states that an employee, officer or partner of an undertaking does not commit an offence under S333A (tipping-off) if the disclosure is to an employee, officer of partner of the same undertaking. However, a small caveat: if a member of staff (including the IP) is one of the subjects of the SAR, then clearly they could not be told as that would be tipping-off.

Are there any updates in relation to the transition to the Financial Conduct Authority being responsible for AML supervision for insolvency practitioners, or timescales?

The short answer is ‘no’. The IPA has seen the plan from the FCA for their 2026 transition work and it is based on information and detail gathering to provide the FCA with better context and understanding of how supervision is undertaken across sectors, and what specific training and guidance will be needed. No detail on legislative changes or proposed timescales for a phased transition to the FCA has been provided, nor indicative timescales given.  

We do a SAR for e.g. BBL misuse, but it is found too late for DAML after we’ve already received payment from the company and established a business relationship months ago?

We have assumed that your question relates to director or company funds for the Statement of Affairs and calling of the decision procedure to place the company into CVL, and then your SIP 2 investigations indicated that there was BBL misuse and was thus reported.

Assuming the company has traded since BBLs concluded in 2021, you would be entitled to assume that the funds used to pay the pre-appointment costs were from trading or director funds, not BBL misuse.  A SAR may be required in relation to the BBL application and/or use of funds, or if you retrospectively established that the funds you accepted were tainted. A DAML can only be submitted if you have a concern that a future and specified transaction relates to tainted funds.

If there is an overdrawn DLA that the director is unable to repay, should a SAR always be submitted for tax evasion and if not, when should you?

As advised during the webinar there is no list or confirmation that the IPA (or any regulator) can provide that categorically states ‘this is when a SAR is required and anything not in the list is when a SAR is not needed’. It depends on whether you have a suspicion of MLTF that has taken place or some sort of criminal or fraudulent activity is suspected.

 If you consider that the DLA issue does create a suspicion for a SAR then report this to your MLRO. You cannot be criticised for doing so. Also ensure that you report your suspicion to the Insolvency Service for CDDA purposes and you may also need to report to HMRC and Report Fraud, and if you consider this to be a criminal matter, to the police. A SAR does not prevent you reporting to other agencies, in the same way reporting to other agencies does not equate to having completed a SAR.

Consultations

Corporate Civil Enforcement Reform Consultation

The Insolvency Service has published the Corporate Civil Enforcement Reform Consultation (‘Consultation’), which seeks views on a number of options that would update the existing corporate civil enforcement regime administered by the Insolvency Service and add new flexibilities for dealing with varying degrees of corporate abuse.

Member Survey

To help shape our response to the Consultation and have a real opportunity to shape government policy that directly affects the restructuring and insolvency profession, we kindly ask that you complete a survey. 

Please note that the questions in our survey (15 in total) are specifically selected and phrased to address the interests of Insolvency Practitioners. While they correspond to the themes in the Annex B section of the Consultation, they may not follow the same numerical order or verbatim phrasing as the forty-nine questions in the original document.

Complete our survey here.  

The deadline for your responses to be provided to the IPA is Friday 15 May 2026. 

Companies House

Guidance – Web Filing issue: information and updates

Companies House has published guidance (updated 8 April) for users to address concerns following a security issue which meant that a logged-in registered user of our Web Filing service could potentially access and change another company’s details without their consent after performing a set of specific actions.

Read the guidance here.

HMRC

New Digital Process for Economic Crime Levy (‘ECL’) in Insolvency

HMRC has released Insolvency Practitioner Bulletin 1 (2026), introducing a streamlined digital approach for handling the Economic Crime Levy when an entity becomes insolvent.

Key takeaways for IPs:

• New Online Form: You must now use the dedicated online form to submit ECL returns and cancel registrations.
• Updated Handbook: Section 28 of the Insolvency Practitioner’s Handbook has been updated with specific guidance for insolvent entities.
• Efficiency: The goal is to speed up correspondence and ensure accurate deregistration.

Read the full bulletin here.

Insolvency Service

Update – INSSight Roll Out

“Fees and Complex interest calculations

Work is still underway to fully resolve the outstanding fee and historical interest issues. As mentioned previously, ‘Simple’ interest cases continue to be processed and closed (including the removal of interest where only simple accrual calculations are required). We appreciate your continued patience while we continue resolving final issues with cases requiring recalculation of ‘Complex’ historical interest.”

“Case closures

Cases with straightforward nil, credit, or debit balances are still being closed, but some may take slightly longer while the remaining interest-related work (mentioned above) is completed.”

“Transfers of monies

We’ve identified the root cause of the issue affecting the movement of receipts between and within cases. A fix has been developed that will be deployed once various fee and interest issues have been resolved.”

“Find an IP

The Find an IP (‘FIP’) service remains linked to INSSight. The following issues are still being addressed:

• IP address first and second lines not displayed.
• Recognised Professional Body website links and telephone numbers not displayed.

Work to resolve these issues is ongoing, and we’ll provide a further update in due course.”

“Banking fee

The quarterly banking fee was applied on 1^st April 2026.”

“Bi- Annual Interest

Please note that the bi‑annual interest due in April has been delayed for a short period and will be applied as soon as possible.”

“What you need to do.

Please continue to request removal of interest ahead of final payments and closure. This can be done by emailing EAS Customer Services (see below) or by ticking the ‘case closure’ box on CAU payment forms.”

“Next steps

We will provide a further update as soon as we have confirmed timelines for completing the Complex interest recalculations and associated fee resolutions.

Thank you very much for your continued cooperation.”

“Support Contact Details

If you require support, please contact:”

Estate Accounts and Scanning (EAS) Customer Services

• Email: [email protected]
• Telephone: 0303 003 1742 

Senior Official Receiver Team

• Email: [email protected]

General queries

Email: [email protected]

Legislation

The National Minimum Wage (Amendment) Regulations 2026 (Effective 1 April 2026)

The regulations increase the pay requirements across all age bands and categories as follows:

Northern Ireland

The Insolvency (Amendment) Bill

On 24 March 2026, the Insolvency (Amendment) Bill (Bill) has passed its Final Stage in the Northern Ireland Assembly as of 24 March 2026 but is not yet fully in force. Following the Assembly’s approval, the draft Bill is awaiting Royal Assent. Once it receives Royal Assent, it will officially become an Act.

This legislation updates Northern Ireland’s insolvency framework to align with Great Britain, aiming to increase consistency and bolster investor confidence. The draft Bill includes measures to assist companies in financial difficulty.

Key changes include:

• Electronic communication: Permits electronic notices and websites for sharing documents.
• Meetings: Removes the requirement for annual meetings in voluntary liquidations.
• Creditor protection: Eases restrictions for banks regarding accounts for undischarged bankrupts.
• Insolvency Practitioners: Authorisation will be handled by professional bodies rather than the Department.

The Disqualified Directors Compensation Orders (Fees) Order (Northern Ireland) 2026

The Order allows the Department for the Economy to charge a fee for the service of distributing money received via compensation orders or compensation undertakings to the relevant creditors. The Order came into effect from 17 April 2026.

The Payment and Electronic Money Institution Insolvency (Northern Ireland) Rules 2026

These Rules provide the detailed procedural framework for the special administration of failing payment institutions (PIs) and electronic money institutions (EMIs) in Northern Ireland. These Rules supplement the broader “Payment and Electronic Money Institution Insolvency Regulations 2021,” which introduced a bespoke insolvency regime for these sectors across the UK. The Rules came into force on 2 March 2026.

Redundancy Payments Service

Form – Redundancy payments: Template for setting up a new case

Template to request setting up a new redundancy case – form is available here.

Guidance – Setting up a case for redundancy payments

If you’re an insolvency practitioner, find out how to use the template for setting up a new case.

Guidance is available here.

Scotland

Accountant in Bankruptcy – System updates and releases

From Wednesday 1 April 2026, all Accountant in Bankruptcy (AiB)-related system updates will be issued through their push notification service.

What this means

Release notes and system updates for ASTRA, BASYS, eDEN, CFT and ROI will no longer be emailed directly to system users.

Action required

If you would like to continue receiving updates by email, please subscribe to their mailing list and select the relevant system(s) under System updates and releases.

Independent Review of Scotland’s Statutory Debt Solutions

The AiB recently hosted a webinar on 01 April 2026 to provide greater understanding of this important piece of work.

Background

In September 2019, Scottish Ministers committed to undertake a wide-ranging policy review of Scotland’s statutory debt solutions. This was in response to a recommendation put forward by the then Economy, Energy and Fair Work Committee following their scrutiny of the Debt Arrangement Scheme (Scotland) Regulations 2019.

Stakeholders agreed that the review should consist of three stages.

Stage 1 – an examination of immediate priorities that could be taken forward during the Parliamentary session. Stage 1 concluded with the Bankruptcy (Miscellaneous Amendments) (Scotland) Regulations 2021 coming into force on 29 March 2021.

Stage 2 – was undertaken by three stakeholder-led working groups, with a remit to consider the operation of existing statutory debt solutions and provide recommendations for improvement. Having considered the recommendations put forward by the three working groups, the Scottish Government developed specific proposals and issued a public consultation to seek further views.

The proposals were introduced in the Bankruptcy and Diligence (Scotland) Act 2024 which came into force on 15 July 2024. The Act is being commenced in stages to factor in other associated work required, for example amendments to court rules and further stakeholder engagement.
The remaining proposals have been / will be taken forward through a mix of secondary legislation and operational guidance. The secondary legislation introduced so far is as follows:

• The Bankruptcy and Debt Arrangement Scheme (Miscellaneous Amendment) (Scotland) Regulations 2023
• The Protected Trust Deeds (miscellaneous Amendment) (Scotland) Regulations 2024
• The Bankruptcy (Scotland) Amendment Regulations 2024

Stage 3 – a longer-term strategic review of Scottish statutory debt solutions to assess if they meet the needs of a modern economy. It has been run independently of AiB and the Scottish Government. Stage 3 formally launched in March 2024 with a stakeholder roundtable, followed by a public call for evidence and a public consultation setting out proposals to reshape the regime. Two nationally representative surveys were also carried out by ScotPulse on behalf of the review team.

The final report from the independent review of statutory debt solutions was published on 12 March 2026 (Report) and is available here.

Purpose of the Review

The review finds that while Scotland’s existing debt solutions largely work as intended, significant reforms are required to improve access, consistency, capacity, fairness and relevance – particularly for people facing complex financial challenges and for the self‑employed.

Key findings

• Debt is rarely a standalone issue and is often intertwined with housing, health, welfare, employment and wellbeing.
• Access to advice is insufficient, with capacity gaps in both free and specialist provision, particularly for minoritized groups and small business owners.
• The language and culture surrounding insolvency can reinforce stigma and deter people from seeking help early.
• Standards and creditor behaviour are applied inconsistently across the system.
• The regime does not adequately serve self‑employed people and small businesses, a growing and economically vital group.
• Financial thresholds and allowances have not kept pace with inflation, reducing effectiveness over time.

Core recommendations (priority areas)

The Report makes 52 recommendations in total. Four core areas are identified for urgent action due to their potential for the greatest impact.

1. Setting the right tone for the regime

• Introduce a clear statutory purpose for the insolvency system, balancing fairness for people in debt with creditor interests.
• Adopt three guiding principles: Justice, Responsibility and Future‑focus.
• Modernise language across the system to be person‑centred and stigma‑reducing.
• Align standards for advisers, insolvency practitioners, creditors and regulators with the FCA Consumer Duty.
• Uprate all monetary limits and allowances annually in line with inflation.

2. Better joining‑up the system

• Deliver a “no wrong door” approach, linking debt advice with welfare, housing, health and employment services.
• Improve referral pathways and responsible data sharing to reduce duplication.
• Commission a feasibility study for a national “tell us once” system.
• Strengthen collaboration between the Accountant in Bankruptcy (AiB), the FCA, Scottish Government and UK Insolvency Service.
• Reform credit reference reporting to better reflect compliance with statutory solutions and reduce barriers to seeking help.

3. Access, capacity and expertise

• Assess national demand for debt advice and establish a plan to meet it.
• Expand and stabilise funding, including by broadening the debt advice levy to more creditor sectors.
• Improve use of technology to increase efficiency and reach.
• Make independent, impartial debt advice mandatory before entry into formal insolvency solutions.
• Strengthen income maximisation and budgeting support as a core part of advice.

4. Supporting the self‑employed and small businesses

• Co‑design new or amended insolvency solutions that allow viable businesses to continue trading, with flexible repayment and appropriate debt relief.
• Increase specialist debt advice for self‑employed people in the short term through government funding.
• Use an expanded levy to support sustainable, long‑term provision.

Conclusion

The review concludes that Scotland has a strong foundation for a fair and effective personal insolvency regime but must now evolve to meet modern economic and social realities. Implementing the recommendations – particularly the four core areas – would deliver a more compassionate, accessible and future‑focused system, with the ambition of making Scotland’s insolvency regime among the most effective in the world.

Other

The National Archives – Guidance for Insolvency Practitioners

The National Archives (NA) has asked the IPA to share the NAs’ guidance for Insolvency Practitioners (IPs) (Guidance). This Guidance provides IPs with a framework to safeguard records of historical (archives) of value when a business or charitable organisation fails.

Examples of collaboration

“Insolvency professionals have a critical role in ensuring that the archives of businesses are not lost or destroyed in cases of administration, liquidation, or closure. These records tell the story of a business and the people who worked for it; they can also be part of history at local and national levels. This guidance is designed to help you play your part to safeguard archives and work collaboratively with colleagues in the archive sector to ensure archives’ survival for future generations.”

Philippa Turner, Sector Development Manager for London and Business Archives at The National Archives and member of the Crisis Management Team for Business Archives

Reminder – Funding the recovery – are insolvency and restructuring cases becoming uneconomic?

FromCounsel are inviting Insolvency Practitioners to take part in a short, anonymous survey. The survey takes approximately 7 minutes.

This is an opportunity to share candid feedback on the issues that matter to you in practice – and to ensure those views are heard.

Responses will inform FromCounsel’s ongoing conversations around best practice and future guidance and help shape the knowledge service it is launching for R&I professionals.

For further details about FromCounsel, please click here.

AML Reform Firm Experience Research

The Financial Conduct Authority (FCA) is inviting firms and sole practitioners to take part in research about their experience of AML supervision today.

This 1-to-1 session will inform the design of the future FCA led supervisory model as the FCA is in the early stages of shaping what this will look like.

Taking part is voluntary. The session is confidential, and no preparation is required.

If you would like to express interest, please complete the form here.

A member of the FCA research team will then contact volunteers directly to arrange a suitable time.

Please express your interest by 1 May 2026 for priority consideration in the initial rounds of research.

If you have any queries regarding any of the contents of this edition of Technical Insights, please do not hesitate to contact Ben Luxford, Technical Lead, by email: [email protected].