FRC publishes 2024/2025 Annual Enforcement Review

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Published: 24 July 2025

The Financial Reporting Council (FRC) today published its seventh Annual Enforcement Review which provides an overview of the FRC’s case assessment, investigations and enforcement activity for the period 2024-2025.

In support of the FRC’s improvement role, the Review examines the principles underpinning the notable cases concluded in the last year. It explains how the principle of proportionality continues to be applied to shape and inform the FRC’s approach to delivery of fair, consistent and evidentially robust outcomes. This year nine investigations were concluded by way of settlement, two were closed with no further action and 12 matters were resolved through constructive engagement. Financial sanctions totalling £14.5m were imposed.

Timeliness of outcomes has remained a particular focus. This year 90% of applicable investigations were completed or resolved within two years, exceeding by a significant margin both the relevant KPI (50%) and performance in all prior years as measured against this benchmark since it was introduced. The FRC’s three-year KPI was also met. These results were achieved in the context of a further year of consolidation and a reduction in headcount.

The Review also notes the FRC’s ongoing project to review and refresh its end-to-end enforcement approach from initial case assessment to publication of final outcomes. The End-to-End Enforcement Review (E2E Review) will examine all aspects of the process including governance, and key decision-making. The focus of the E2E Review includes the introduction of a graduated range of regulatory responses as part of bolstering the FRC’s toolkit in support of proportionality and building on the progress made on timeliness in recent years. Stakeholder engagement has been supportive, ahead of a public consultation later this year.

Elizabeth Barrett, FRC Executive Director of Enforcement, said:

“Whilst in recent years there has been positive progress on increasingly timely delivery of fair, evidentially robust outcomes, the procedural options currently available to the FRC limit significant further improvement.

“The E2E Review is a major initiative straddling work in Supervision, Enforcement and our Legal Services team, which aims to take matters to the next level. The proposed introduction of a graduated range of responses is designed to ensure that our approach remains adaptable, market-responsive and serves the public interest while reducing unnecessary burdens.”

Read the Annual Enforcement Review

Listen to the FRC's latest In Conversation podcast episode about this, featuring Kate O'Neill, Director of Stakeholder Engagement and Corporate Affairs and Elizabeth Barrett, Executive Director of Enforcement and Executive Counsel.