Insolvency technical update: October 2026

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

ICAS AML Supervision Report 2025/26

We've recently published our annual AML supervision report. This includes:

• Details on our approach to AML supervision.
• Results of monitoring visits during the relevant period.
• Early findings from thematic reviews.
• Common findings, with case studies demonstrating best practice.
• Examples of enforcement and follow-up actions.
• Information on AML support for supervised firms.

Read the report

Financial Action Task Force (FATF) ‘grey’ list updated

FATF has updated its list of countries subject to increased monitoring (the ‘grey’ list) following their October 2026 plenary session. Bulgaria, Democratic Republic of Congo, Ivory Coast and Monaco have all been removed.

For UK AML purposes, enhanced due diligence is required where there is a connection with a country included on the FATF list of countries subject to a call for action (the ‘black’ list). No changes were made to that list.

Geographic risk needs to be considered as part of the customer due diligence risk assessment. The risk associated with countries on the grey list therefore still needs to be considered.

Firms should ensure that policies and procedures reflect the updated position. They should also consider whether they need to update any customer due diligence risk assessments and whether the change affects their firm-wide risk assessment.

Access the current FATF black and grey lists

The Bankruptcy and Attachment (Miscellaneous Amendment) (Scotland) Regulations 2026 

Draft regulations have been laid in the Scottish Parliament which will change Scotland’s Minimal Asset Process (MAP) bankruptcy route by giving more people with limited debts and assets access to debt relief. 

If the Scottish Parliament approves the changes, they’ll take effect on 1 April 2027, increasing debt and asset thresholds and strengthening protection for essential assets.

Find out what’s changing

VAT 700/56 (Insolvency)

Sections 9, 11, 14, 22, 24 and 26 have been removed from the VAT Notice. They have been replaced with links to the relevant sections of the Insolvency practitioner's handbook.

SIP 3.1 consultation

The Joint Insolvency Committee is consulting on proposed changes to Statement of Insolvency Practice 3.1 – Individual Voluntary Arrangements. 

Find out why it’s being revised, what could change and how to share your views on the proposed changes. The consultation response deadline is 8 December 2026.

Objections to Companies House striking off

After 1 December 2026, objections to limited companies being struck off the Companies House register will need to be submitted through the Companies House online service. 

Legal updates

Hinton v Stobinski (Re St Mark Lions Ltd) [2026] EWHC 2386 (Ch) 

A recent High Court judgment clarifies the distinction between an ordinary director’s debt recovery and misfeasance. It also highlights the evidence needed to show that a director's conduct caused loss to an insolvent company.