What this means
Start with the exact decision in front of you.
The FRC's Audit Enforcement Procedure applies to the statutory-audit matters within its scope and differs from a professional body's general disciplinary process. Current routes can include investigation, decision notice, settlement, accelerated procedure or tribunal.
Immediate priorities
Organise the position before responding.
Confirm that the notice invokes the current AEP
Map each proposed breach to the relevant audit requirement
Coordinate firm, individual and audited-entity evidence
Detailed guidance
The procedure, evidence and possible route from here.
01
Confirm AEP scope and the current procedure
The FRC is the UK competent authority for statutory audit and uses the Audit Enforcement Procedure for matters within its stated scope. Current FRC guidance describes audits of public-interest entities, specified large AIM companies and Lloyd's syndicates, with other audit investigations generally delegated to recognised supervisory bodies unless reclaimed. Check the engagement, audit period, respondent and notice to confirm why the FRC is acting and which version of the AEP applies.
The procedure revised in July 2026 includes initial enquiries, investigation and routes such as settlement, Early Admissions and Accelerated Procedure, with Tribunal determination where matters remain unresolved. Do not use an archived AEP or assume that an earlier case followed the current route. Record whether the document is an information request, Notice of Investigation, Decision Notice, proposed settlement or tribunal pleading; each calls for a different response.
- Verify the audit falls within FRC scope
- Use the AEP version stated in the notice
- Identify the exact procedural document received
02
Answer proposed breaches of Relevant Requirements
Map each proposed breach to the Relevant Requirement, audit role and evidence. Preserve working papers with review history and identify the information available at the relevant time. A later company failure or restatement does not by itself prove how the audit work measured against the applicable requirement, while a clean opinion does not answer a documented performance failure. Technical analysis should expose assumptions and distinguish firm systems from individual decisions.
Executive Counsel's investigation may culminate in a Decision Notice setting out proposed breaches and sanctions. Review facts, breach reasoning, respondent attribution and sanction separately. If a self-review or accelerated route is proposed, understand the scope, independence, privilege and use of resulting admissions before beginning. Cooperation should be candid, but an internal review must not be engineered toward a predetermined admission or used to overwrite the historic audit file.
- Build a requirement-and-evidence matrix
- Separate firm and individual conduct
- Define any self-review before work begins
03
Choose between acceptance, settlement and Tribunal
An investigation subject may accept proposed breaches and sanctions, negotiate settlement where available, or contest unresolved matters that proceed to the independent Tribunal. Agreed Decision Notices and settlements require the approvals described in the current AEP, and publication of sanctions is mandatory under the FRC's outline. Assess admissions, financial and non-financial sanctions, costs, publication and other regulatory consequences as one decision.
If the case proceeds, the Tribunal determines whether Relevant Requirements were breached and can impose sanctions after an Adverse Finding. Prepare evidence around each requirement and preserve any unused-material or disclosure issue through the formal route. A respondent should also plan for market, client and professional-body notifications without presenting allegations as proven. Obtain the final Notice or Tribunal decision, approval and publication text for a complete record.
- Assess all settlement consequences together
- Use the independent Tribunal route for unresolved breaches
- Keep the final approved and published documents
Key questions
Keep the analysis tied to this stage.
Whether a Relevant Requirement may have been breached
Whether proposed breaches and sanctions can be accepted
Whether unresolved matters require an independent Tribunal
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Does the AEP apply to every UK audit?
No. The FRC describes its direct scope and the delegation of other audit-related investigations to recognised supervisory bodies, subject to its ability to reclaim matters.
What changed in July 2026?
The FRC brought a revised AEP and supporting policies into effect, including broader routes to resolution. A live matter must use the procedure and policies applicable to it, not an archived version.
Connected guidance
Continue through the topic map.
Use the hub for the full sequence or choose the connected route that matches the notice.
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.