Insolvency technical update: January 2026

Read our latest insolvency technical update – your round-up of the recent developments in insolvency.

Contacting HMRC’s Member Voluntary Liquidation (MVL) team

From 2 February, the only way to contact HMRC’s MVL team is by completing the dedicated online form. Full information on this change was set out in HMRC’s IP Bulletin 9 (2025).

AiB Notes for Guidance (Common Financial Tool) update

Section 6.8 (Essential Expenditure) has been updated to reflect the increase in the gas and electricity price cap, effective from 1 January 2026. The limit for which no supporting evidence is required for utility spend has increased from £146 to £146.50 per month from 1 January 2026 to 31 March 2026.

Dear IP

The Insolvency Service have issued Dear IP 169, which includes reminders about information issued by the Recognised Professional Bodies on the handling of car finance claims, the High Court decision about MVLs and joint nominee agreements. It also reminds insolvency practitioners about requirements to retain records where criminal investigations against directors are being undertaken. 

UK sanctions

From 28 January 2026, the OFSI Consolidated List of Asset Freeze Targets and its search tool were closed. The list remains available for reference but will no longer be updated. The UK Sanctions List is the only source for all UK sanctions designations.

The UK Sanctions List search tool has been improved. Changes include the introduction of fuzzy logic search and improved ranking of search results by relevance. Some other minor amendments have been made to sanction publications. A guidance page is available which sets out all changes.

Insolvency practitioners should ensure that firm checklists and procedures are updated, and that reference is made only to the UK Sanctions List when it is necessary to check that people or an entity isn’t sanctioned.

OFSI and HMT have also issued updated Financial sanctions guidance for Insolvency Practitioners.

Delay to introduction of mandatory Authorised Corporate Service Providers (ACSPs) requirement for Companies House filings

Companies House has announced a delay to the planned requirement for presenter information and third-party agents filing to be registered as ACSPs. The changes, originally planned for spring 2026, will take effect no earlier than November 2026. Further guidance on the impact of the new requirements on insolvency practitioners will be issued in due course.

INSSight Rollout Update

The Insolvency Service has issued an update on the rollout of the new INSSight case management system. Find out about known issues, fixes, new templates and guidance.

New Insolvency Service templates

The Insolvency Service has published new templates for insolvency practitioners use. These cover notifications of bulk case transfers and bulk Individual Voluntary Arrangement registrations.

Employment Rights Act 2025

The Employment Rights Act 2025 will introduce significant changes to employment law in Scotland, England and Wales over the next two years. Our article sets out a summary of the main changes .

MVL to CVL conversion – director conduct report requirements

Insolvency practitioners are reminded that, under section 7A The Company Directors Disqualification Act 1986, a Directors’ Conduct Report must be submitted within a period of three months from the date the insolvency practitioner forms the opinion that the company is unable to pay its debts in full. The consideration of whether the creditors will ultimately be paid in full isn’t relevant to the requirement to submit the report.

Ethics CPD requirement

ICAS introduced a change to CPD requirements. From 1 January 2026, all non-retired members are required to complete 1 hour of mandatory ethics CPD each year. Find out more about how to record and confirm your annual ethics CPD, as well as some useful resources to get you started. 

Legal updates

Revenue and Customs Commissioners v Purity Ltd [2025] EWHC 3401 (Ch) 
The High Court considered the first ever public interest winding-up petition under new HMRC powers. It decided that it would be appropriate to wind up the company, despite it being in Creditor’s Voluntary Liquidation (CVL). This was because section 8ZF of the Company Directors Disqualification Act 1986 provides for compulsory disqualification if HMRC makes a relevant application in respect of a director or shadow director of a company wound up under section 85 of the Finance Act 2022, which wouldn’t be available in CVL.

Webb and another (as joint liquidators of Eversholt Rail (365) Ltd (in liquidation)) v Eversholt Rail Ltd and another company [2026] EWHC 101 (Ch) 
The High Court rejected the appeal for disclosure of a wide range of documents under section 235 and section 236 of the Insolvency Act 1986. The judge confirmed that a "reasonable requirement" is necessary for section 235. Case law also supports the same requirement for section 236.