Insolvency technical update: September 2025

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

Interim guidance on the handling of car finance claims in insolvency appointments

Interim guidance has been issued setting out expectations in relation to personal insolvency appointments following the recent Supreme Court judgment in relation to car finance claims and a proposed FCA scheme to compensate car finance customers who have been treated unfairly.

Covid support voluntary repayment scheme

A voluntary repayment scheme has been launched which provides Covid scheme recipients with a ‘no questions asked’ window to repay outstanding money they were not entitled to or did not need.

Repayment under the voluntary repayment scheme does not guarantee any protection to directors from enforcement action and insolvency practitioners should continue to report misconduct in the usual way through the director conduct reporting service, including whether they are aware of any repayment being made.

Where an Insolvency practitioner becomes aware of a possible fraud outside of an insolvency situation they should report it to the appropriate authorities.

Use of testimonials or reviews as part of marketing activity

If you publish or refer to client reviews or testimonials as part of your marketing activity, the Digital Markets, Competition and Consumers Act 2024 impose certain requirements. Find out more about these requirements to keep you compliant in this ICAS article.

Advance notification of redundancies - HR1

The HR1 form can now be completed and submitted digitally via gov.uk. 

From 1 December 2025 paper based forms will not be accepted.

Suspicious Activity Reporting Best Practice Videos

A series of short UKFIU videos on suspicious activity reporting best practice have been released. These cover a range of topics relevant to anyone involved in firms' AML processes, but especially MLROs and MLCPs. Watch now

Financial sanctions

A new list of financial sanctions against Russia has been issued by HM Treasury. Firms should ensure that their AML financial sanctions checks include these updated targets. 

Code of ethics for insolvency practitioners

A revised code of ethics for insolvency practitioners has been issued and will come into effect on 1 October 2025. The revisions relate primarily to professional behaviour, role and mindset and technology.

Insolvency Guidance Paper 5 – Dealing with Complaints

The Joint Insolvency Committee together with the Recognised Professional Bodies – ICAS, ICAEW and IPA - have approved and issue updated guidance to insolvency practitioners on dealing with complaints, which will come into effect on 1 October 2025.

The principal revisions to IGP 5 involves the introduction of a more hierarchical structure outlining general considerations and more detailed recommended practical steps to be taken by IPs.

AiB Notes for Guidance (Common Financial Tool) update

Section 6.8 (Essential Expenditure) has been updated to reflect the increase in gas and electricity price cap effective from 1 October 2025. The limit for which no supporting evidence is required for utility spend is increased from £143 to £146 pm from 1 October to 31 December 2025.

Legal update

Pagden & Ors v Fry & Anor [2025] EWHC 2316 (Ch) A recent High Court judgment has highlighted that limitation of liability clauses, a common feature in accountancy letters of engagement, are largely ineffective in relation to insolvency appointments.