Audit Enforcement Procedure: Consultation on proposed updates to the FRC’s routes to resolution

Published: 1 October 2025

Response deadline: 9 January 2026

Consultation document
Links to PDFs open in new tabs
Title Audit Enforcement Procedure: Consultation on proposed updates to the FRC’s routes to resolution
Format pdf, 478.5 KB

Overview

The FRC consulted on proposed revisions to the Audit Enforcement Procedure (AEP).

The Financial Reporting Council’s (FRC) enforcement activity plays an important role in delivering its core work in support of the public interest and UK growth. In 2024, the FRC commenced a review of its end-to-end enforcement processes which considered its governance structures, decision-making processes and the operational efficiency and effectiveness of the AEP.

The FRC isconsulted on proposed changes to the AEP that will facilitate further improvement to the end-to-end process, including:

  • making more explicit how the public interest is embedded in the decision-making process and in line with how the Conduct Committee currently consider cases, and introducing senior involvement of the case assessment process to give the Conduct Committee additional assurance.
  • allowing the FRC through its Conduct Committee to have a more graduated and broader range of interventions available to resolve cases according to their individual facts.
  • enabling the faster completion of cases and delivery of outcomes which supports the FRC’s deterrent and educative objective while reducing expenditure.
Documents
Name Appendix A (Audit Enforcement Procedure)
Publication date 1 October 2025
Type Consultation paper
Format PDF, 946.0 KB
Name Appendix B (Table of Amendments)
Publication date 1 October 2025
Type Consultation paper
Format PDF, 520.2 KB
Name Audit Enforcement Procedure Consultation explainer
Publication date 10 December 2025
Type Information sheet
Format PDF, 409.3 KB. View HTML version

Roundtables

The FRC held a series of roundtables throughout the consultation period on proposed revisions to the Audit Enforcement Procedure, which is part of the wider end-to-end enforcement process review launched in 2024. This was an opportunity for stakeholders to share their views on the questions asked in the consultation, and explore issues in more detail.

The FRC was keen to hear feedback and comments from across the stakeholder environment, including audit firms, professional bodies, law firms and users of audited financial statements.

Roundtables took place on Microsoft Teams or in-person at the FRC's offices, and places were allocated on a first-come, first-served basis, and confirmed via email.

Roundtable sessions
Date
and time
Group Virtual/In person
Thursday 6 November 2025, 11:30 – 13:00 Recognised Supervisory Bodies Virtual
Wednesday 12 November 2025, 09:00 – 10:30 Audit firms In person
Thursday 13 November 2025, 14:00 – 15:30 Users of audited financial statements Virtual
Monday 17 November 2025, 14:00 – 15:30 Audit Committee Chairs Virtual
Thursday 20 November 2025, 09:30 – 11:00 Audit firms Virtual
Tuesday 25 November 2025, 09:30 – 11:00 Law firms In person

Consultation responses

Responses received
Links to PDFs open in new tabs
Title 01 ACCA response to AEP Consultation
Format pdf, 86.5 KB
Title 02 AIC response to AEP Consultation and others
Format pdf, 222.5 KB
Title 03 APA response to FRC AEP Consultation
Format pdf, 502.4 KB
Title 04 BDO response to AEP Consultation
Format pdf, 159.7 KB
Title 05 Chartered Accountants Ireland response to AEP Consultation
Format pdf, 89.4 KB
Title 06 Clyde & Co response to AEP Consultation
Format pdf, 167.0 KB
Title 07 CPA Australia response to AEP Consultation
Format pdf, 151.2 KB
Title 08 Crowe response to AEP Consultation
Format pdf, 144.9 KB
Title 09 DAC Beachcroft response to AEP Consultation
Format pdf, 141.7 KB
Title 10 Deloitte response to AEP Consultation
Format pdf, 172.0 KB
Title 11 EY response to AEP Consultation
Format pdf, 267.9 KB
Title 12 Forvis Mazars response to AEP Consultation
Format pdf, 256.7 KB
Title 13 Grant Thornton response to AEP Consultation
Format pdf, 117.3 KB
Title 14 Group A response to AEP Consultation
Format pdf, 284.8 KB
Title 15 ICAS response to AEP Consultation
Format pdf, 293.6 KB
Title 16 ICGN response to AEP Consultation
Format pdf, 211.8 KB
Title 17 Investment Association response to AEP Consultation
Format pdf, 227.8 KB
Title 18 KPMG response to AEP Consultation
Format pdf, 392.5 KB
Title 19 Moore Kingston Smith LLP response to AEP Consultation
Format pdf, 221.7 KB
Title 20 Price Bailey response to AEP Consultation
Format pdf, 693.2 KB
Title 21 PWC PIB AOB response to AEP Consultation
Format pdf, 135.9 KB
Title 22 PwC response to AEP Consultation
Format pdf, 294.9 KB
Title 23 RPC Legal response to AEP Consultation
Format pdf, 80.7 KB
Title 24 RSM response to AEP Consultation
Format pdf, 140.5 KB
Title 25 SME Alliance response to AEP Consultation
Format pdf, 163.2 KB
Title 26 Taylor Wessing response to AEP Consultation
Format pdf, 196.8 KB
Title 27 UKSA response to AEP Consultation
Format pdf, 186.2 KB

Consultation status: closed