What this means
Start with the exact decision in front of you.
The Accountancy Scheme covers members and member firms of participating professional bodies in qualifying public-interest cases, principally outside current statutory-audit enforcement. Its misconduct test and formal-complaint route should not be conflated with the AEP.
Immediate priorities
Organise the position before responding.
Confirm participant membership and non-audit scope
Identify the public-interest basis for investigation
Prepare representations to any Proposed Formal Complaint
Detailed guidance
The procedure, evidence and possible route from here.
01
Confirm participant and public-interest scope
The FRC Accountancy Scheme covers members and member firms of participating professional bodies, including ICAEW and ACCA, for qualifying cases within the Scheme. Its present scope is principally non-audit because statutory-audit enforcement moved to the AEP. Confirm participant membership, the work in question and why the FRC considers the case to raise important UK public-interest issues. A professional-body complaint does not automatically satisfy the Scheme's entry criteria.
Current FRC material identifies factors such as impact on many people, significant financial loss and confidence in UK financial reporting or corporate governance. The Board or Conduct Committee decides whether reasonable grounds exist to suspect Misconduct and whether investigation should begin. Preserve the referral or own-initiative basis and any publication decision. The commencement decision is not a finding that Misconduct occurred.
- Verify membership of a Scheme participant
- Separate non-audit scope from AEP matters
- Identify the stated public-interest basis
02
Prepare for investigation and proposed complaint
Executive Counsel's investigation is conducted by lawyers and forensic accountants and may use external experts or counsel. Map information requests to the respondent, source and issue. The general duty to cooperate operates under the Scheme, while confidentiality and privilege still require precise handling. Keep original financial records and work product unchanged. Any later technical report should state the standards, instructions, assumptions and information considered.
If Executive Counsel considers that there is a realistic prospect of an Adverse Finding and a hearing is desirable in the public interest, a Proposed Formal Complaint is delivered. The current FRC outline provides a period for representations before a Formal Complaint decision. Use the period stated in the served document. Address pleaded Misconduct, evidence, respondent attribution and public interest separately, and identify any material evidence omitted from the proposed case.
- Log all required information and productions
- Keep expert assumptions visible
- Respond to every element of the Proposed Formal Complaint
03
Understand settlement and Tribunal determination
After representations, Executive Counsel may end the process or deliver a Formal Complaint if the relevant tests remain met. An independent Disciplinary Tribunal then determines whether to make an Adverse Finding. The Tribunal route is different from an ICAEW or ACCA committee hearing even where the respondent belongs to that body. Confirm the governing Scheme and regulations for evidence, disclosure, hearing and appeal.
Settlement may be discussed after investigation begins and before final determination. Review the agreed facts, Misconduct admission, sanction, costs, publication and professional-body effects. A settlement should not blur non-audit Scheme conduct with any parallel AEP issue. Once a Tribunal or settlement concludes the case, retain the final report, approval and published outcome, and verify any required membership, employer or client notification from the formal text.
- Distinguish Proposed and Formal Complaints
- Use the Scheme tribunal rules for contested Misconduct
- Keep settlement terms confined to the correct regime
Key questions
Keep the analysis tied to this stage.
Whether there are reasonable grounds to suspect misconduct
Whether a tribunal finding has a realistic prospect
Whether a hearing is desirable in the public interest
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Does the FRC Accountancy Scheme cover statutory audits?
Its current role is principally public-interest non-audit misconduct after the AEP took over statutory-audit enforcement. The engagement and notice must still be checked for the applicable regime.
What happens after a Proposed Formal Complaint?
The respondent can make representations within the stated period. Executive Counsel then assesses whether the realistic-prospect and public-interest tests support delivery of a Formal Complaint to a Disciplinary Tribunal.
Connected guidance
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Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.