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ICAEW / ACCA / FRC guide · Work out which accountancy disciplinary process applies

ICAEW, ACCA or FRC: identify the regulator and enforcement regime

ICAEW and ACCA operate their own member and firm disciplinary systems, while the FRC uses separate regimes for statutory audit and specified public-interest accountancy cases. The first task is to identify the body, respondent and procedural instrument.

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ICAEW and ACCA operate their own member and firm disciplinary systems, while the FRC uses separate regimes for statutory audit and specified public-interest accountancy cases. The first task is to identify the body, respondent and procedural instrument.

Immediate priorities

Organise the position before responding.

01

Record every regulator, reference and notice date

02

Identify membership, firm and statutory-audit status

03

Separate audit, non-audit and membership allegations

Detailed guidance

The procedure, evidence and possible route from here.

01

Identify the professional body and respondent

ICAEW and ACCA are distinct professional bodies with their own charters, bye-laws, regulations and disciplinary arrangements. Begin by recording whether the notice concerns an individual member, student, affiliate, firm, principal, licensed practitioner or another person bound by the relevant framework. A complaint against a firm may not engage identical provisions for each individual. Check membership and authorisation status at the time of the alleged conduct, not only the person's present title.

Professional-body discipline can address ethics, conduct, cooperation, licensing and other membership obligations. It is not the same as a civil claim for loss, an employer investigation or a statutory-audit enforcement case. List each alleged standard and the version in force. If the letter uses a generic term such as accountant, confirm the actual jurisdictional link. Holding an accountancy role does not alone explain which body's rules apply.

  • Record the status of every proposed respondent
  • Check rule versions at the conduct date
  • Separate membership duties from private disputes

02

Distinguish the two FRC enforcement regimes

The FRC's Audit Enforcement Procedure applies to statutory-audit matters within the scope described by the FRC, including specified public-interest and large-market engagements, while other audit matters may be delegated to recognised supervisory bodies. The current AEP uses concepts such as Relevant Requirements, Decision Notices, settlement and Tribunal determination. It should not be described as an ICAEW or ACCA disciplinary hearing merely because an audit respondent also belongs to that body.

The FRC Accountancy Scheme is a separate public-interest misconduct regime for members and member firms of participating professional bodies, principally in non-audit matters after the introduction of the AEP. It asks whether public-interest and reasonable-suspicion criteria justify investigation and can proceed through a Proposed Formal Complaint to a Disciplinary Tribunal. Its concept of Misconduct and the AEP's breach analysis are not interchangeable. Identify which instrument the notice expressly invokes.

  • Confirm whether the FRC invokes AEP or the Scheme
  • Classify the work as audit or non-audit
  • Do not merge breach and Misconduct tests

03

Map concurrent and delegated action

One event can interest an employer, professional body, FRC, recognised supervisory body, insolvency regulator, tax authority or law-enforcement agency. Record which body leads each issue and whether a matter has been delegated, retained, reclaimed or referred. Do not assume a professional body lacks any role because the FRC is involved; different people, conduct or membership obligations may remain. Ask for clarity where notices appear to overlap.

Build a regime map showing allegations, governing instrument, decision-maker, deadlines and possible outcomes. Statements may be shared across processes, but each response should answer its own test. Settlement in one forum may not bind another unless the legal framework says so. Consistent facts and careful defined terms reduce the risk that an audit breach is inaccurately admitted as wider professional misconduct, or that an individual accepts responsibility for a firm's systems without analysis.

  • Create one map of every active regulator
  • Identify delegation, retention and referral explicitly
  • Keep admissions confined to the correct respondent and regime

Key questions

Keep the analysis tied to this stage.

Question 01

Which body has jurisdiction over each respondent

Question 02

Whether FRC or professional-body proceedings apply

Question 03

Whether parallel or delegated action is possible

Independent legal help

Advice is provided only by the regulated firm that accepts a matter.

Common questions

Clarifying the route without assuming the outcome.

Can the FRC and a professional body both be involved?

Potentially. Allocation, delegation and the scope of each regime depend on the work, respondent and conduct. The notices and current regulatory arrangements should be compared before assuming exclusivity.

Is every FRC accountancy case an audit case?

No. The AEP concerns statutory-audit enforcement within its scope, while the Accountancy Scheme addresses qualifying public-interest accountancy misconduct, principally outside current statutory-audit enforcement.

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.

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