In Conversation: Consulting to update the Audit Enforcement Procedure
Published: 10 December 2025
8 minute read
For this episode of the Financial Reporting Council's 'In Conversation' podcast series, Kate O'Neill, Director of Stakeholder Engagement and Corporate Affairs, is joined by Anthony Barrett, Executive Director of Supervision, and Jamie Symington, Deputy Executive Counsel, to discuss the progress of the FRC's consultation on proposed amendments to the Audit Enforcement Procedure, which launched in October 2025 as part of its end-to-end review of its enforcement processes, and what we’ve heard so far from stakeholders.
Transcript
00:00:12:07 - 00:00:36:12
Kate O'Neill
Hello there and welcome to another FRC in conversation. My name is Kate O'Neill. I'm the director of Stakeholder engagement and Corporate Affairs here at FRC. And today we're talking about the progress of end to end enforcement process review that is currently underway. So today I'm joined by Anthony Barrett, executive director of supervision, and Jamie Symington, Deputy Executive council here at the FRC.
00:00:36:12 - 00:00:38:07
Kate O'Neill
Welcome, Anthony and Jamie.
00:00:38:10 - 00:00:39:11
Jamie Symington
Hi. Great to be here.
00:00:39:11 - 00:00:41:07
Anthony Barrett
And good to be here as well.
00:00:41:12 - 00:01:10:00
Kate O'Neill
Well, let's just jump into it, Anthony and Jamie, because we're almost at the end of the formal consultation on our proposed update to the FRC's routes to resolution through the audit enforcement procedure, which consultation was published at the beginning of October. So before we delve into what we've heard so far, Anthony, can you quickly remind listeners of what the end-to-end enforcement process review is and how we developed the proposals in this consultation?
00:01:10:02 - 00:01:30:12
Anthony Barrett
Of course Kate. So it's good practice for us, and in fact, any regulator to periodically review systems and procedures and the way we do things so that we can implement kind of continuous improvement based on the learning from how our processes operated and how regulated entities interact with them. So we launched our end to end enforcement process review in 2024.
00:01:30:12 - 00:01:55:24
Anthony Barrett
And we want our enforcement processes to continue to meet the expectations of the modern regulatory landscape and to make sure it facilitates more proportionate and targeted regulatory responses that will ultimately lead to more timely outcomes for all parties. So we've published the consultation. We want to hear from stakeholders. We want their feedback on how we can further enhance the proportionality of our enforcement activity, whilst also maintaining its robustness.
00:01:56:01 - 00:02:20:05
Kate O'Neill
We'll come back to that proportionality point in a minute. So Anthony and Jamie, we've obviously published the consultation and we've been conducting a lot of stakeholder engagement to make sure we're getting the correct broad range of views from those involved and impacted by our enforcement regime. So in both of you, tell us more about what we've been hearing from all stakeholders during this consultation period.
00:02:20:07 - 00:02:38:10
Anthony Barrett
Yeah. And it's really important to get that consultation feedback so we can find out exactly what stakeholders think. So we started this off back in October with a webinar where we invited anyone with an interest to hear about what we were doing, what we were trying to achieve, and to ask any initial questions they had about the consultation document.
00:02:38:10 - 00:03:01:05
Anthony Barrett
And since then, we've been speaking with stakeholders, which includes law firms, audit firms, recognized supervisory bodies, audit committee chairs and users of audited financial statements, both through direct meetings and in a series of really well attended roundtables. And these conversations have been an opportunity for stakeholders to share their thoughts on the proposal, get any clarification that was needed, and ask any questions of us that they may have.
00:03:01:07 - 00:03:27:00
Kate O'Neill
Thanks, Anthony and Jamie. This engagement process, it's not really supposed to be gathering consensus. It is about talking about issues that are raised or challenges, and having that environment to have our stakeholders give us some really interesting and also feedback that is sometimes challenging, but really good to get a range of views rather than focusing consultation too much around what we expect people views to be.
00:03:27:02 - 00:03:46:13
Jamie Symington
That's right Kate, and we've been having some really excellent conversations during the roundtables. We've been getting those comments in orally. We've been having some really good discussions, and we're not starting to see some of the first written comments coming in so that the engagement process is one. It means over there's a while to go yet. And the end of the consultation process, which is on the 9th of January.
00:03:46:13 - 00:03:54:14
Jamie Symington
So we're still really keen to keep these conversations going with anyone who wants to share their views with us, and especially those who represent public interest in our work.
00:03:54:18 - 00:04:15:10
Kate O'Neill
I guess Jamie to me mean going into consultation sits on the tenets of consultation. We haven't got predetermined outcomes in mind. We've obviously put up the proposals, but these have really led to, as you say, some very rich and detailed conversations about not just about what's in the proposals, but about how the FRC will approach whatever decision we make going forward.
00:04:15:12 - 00:04:35:19
Jamie Symington
Absolutely. I agree with that. But overall, actually what we've been hearing is a lot of thought from across stakeholder groups for what we're proposing in this consultation, and we take a lot of comfort from the fact that we haven't so far heard any real concerns from users of audited accounts, that our proposals would undermine their view of the robustness of our enforcement activity.
00:04:35:19 - 00:04:48:13
Jamie Symington
But there is, understandably, a lot of appetite to see more detail, more about how we envisage operationalizing these proposals have taken forward. But to understand how we'll engage with the sector in embedding these changes.
00:04:48:16 - 00:05:11:19
Kate O'Neill
Well, I'm not surprised to hear that because the how of any proposal is always going to be where people next focus their minds on how it's going to be done and how it's going to affect them. So, Jamie, while we're going to be using the formal submissions by stakeholders when considering any changes as we develop the final proposals, has it been useful to have these initial conversations to, I guess, set a bit of a background for our consideration.
00:05:11:20 - 00:05:38:16
Jamie Symington
That's been really useful. And as you say, we'll be using and we'll be considering the feedback provided in the formal submissions when we are considering what the final forms will look like. So we don't want to assume that what we've heard in these conversations would exactly mirror those representations, which are still to come, but it's been great to get the early feedback on how stakeholders are thinking about these proposals and the areas that they support, or where they think we could consider tweaks to what we are proposing.
00:05:38:16 - 00:06:05:09
Jamie Symington
So, for example, clear support across all our engagement for any steps that we can take to support timelier outcomes for all parties. And there's a general feeling that what we're proposing does help with that. But we've also had challenges put to us on what more we can do around the transparency of our enforcement processes, and particularly around the decisions that have taken within the FRC as to how we open investigations or put matters down other routes to resolution.
00:06:05:09 - 00:06:12:15
Jamie Symington
And that's something that we need to consider carefully, because there are competing interests that we need to consider here. So it's a question of getting that balance right.
00:06:12:16 - 00:06:43:00
Kate O'Neill
And it's a great point about the competing interests. We never expected there to be consensus of such a broad stakeholder universe who's affected by our enforcement processes. But actually, there are other obviously large projects underway at the FRC at the moment. And do you think that the crossover between the points raised in the engagement around the end, when enforcement review and what we have been hearing in the future of audit supervision consultations has been a good crossover for us to consider for both projects.
00:06:43:00 - 00:07:08:02
Anthony Barrett
Absolutely, Kate. And it's it's really important for us that both, for example, the E2E review and the future audit supervision strategy work are properly aligned because there is a lot of connectivity between those two aspects. I mean, in some cases, some of our supervisory work feeds directly into enforcement work, and equally, some of the outcomes from enforcement work then feed into our consideration of the supervisory work.
00:07:08:02 - 00:07:24:04
Anthony Barrett
So really important and stakeholders have been raising points clearly within the consultation. But I think that's a sign of, you know, a very good kind of mature relationship between us and the stakeholders and reflects the confidence of stakeholders have that they can raise those issues with us and they will be listened to.
00:07:24:06 - 00:07:49:06
Kate O'Neill
Absolutely. And I know an area that we've heard of both projects is how the FRC approach to audit regulation, through both our supervisory and enforcement activity, may impact the attractiveness of the profession and how we can evolve our approaches in the future. I mean, I guess I see that really relate to individual auditors and their role in perhaps those larger, more complicated audits of larger, more complicated companies.
00:07:49:07 - 00:08:09:07
Anthony Barrett
That's right. And whilst the responsible individual senior statutory order is responsible for individual engagement, they operate within a structure of a firm. And I think as we focus more on firms, a system of quality management, that then puts the focus perhaps slightly more on to the firm and the firms processes and procedures, I guess.
00:08:09:07 - 00:08:30:06
Kate O'Neill
Watch this space on both projects. Anthony, is these type of issues that sound like they've got more of a market consideration, evolve and are considered. So what does success look like? Anthony and Jamie, I mean, as you pointed out, a very important review and we've taken the right length of time to consult widely on it because it's so important.
00:08:30:06 - 00:08:32:19
Kate O'Neill
So, Jamie, what does success look like here?
00:08:32:22 - 00:08:47:20
Jamie Symington
Well, obviously, we need to look at and to consider all the feedback that we gather through this process. And that's why we're so keen to see as many written responses as possible by the deadline of the 9th of January. So if you haven't had a chance to put your comments in yet, there's still time to hear from you and we will update.
00:08:47:20 - 00:09:13:13
Kate O'Neill
So people are going to approach this from a very wide group of stakeholders. What's next? It's certainly not a referendum, Jamie. So, you know, regardless of what the conclusions are and the individual proposals in the consultation, the success of the revised baudit enforcement procedure, whatever it will look like, will really be a bit of a balance between both the FRC and those we regulate to accept everybody's place in this important work.
00:09:13:15 - 00:09:41:19
Jamie Symington
I think that's right. Okay. From what I'm hearing, people from all parts understand the opportunities it presents to deliver speedier outcomes and also the more proportionate range of responses that's on offer. But I think what's really important is that to take full advantage of the new proposals and the new variations to the audit enforcement procedure, people need to really engage with and to make decisions about whether and how to use the processes that we've got.
00:09:41:19 - 00:09:56:09
Jamie Symington
So people really need to lean into these processes and to embrace the changes. And that's why we're so keen to understand from people what their responses to them are, and to understand how we can deliver any improvements to the proposals that we've got. By the end of the consultation process.
00:09:56:10 - 00:10:05:17
Kate O'Neill
Jamie and Anthony, what does success look like in your mind for this? I mean, there's no quick answer, but I like Jamie's point about people leaning in and being part of the answer.
00:10:05:20 - 00:10:24:15
Anthony Barrett
Yeah, I mean, that's absolutely right. I think it's in all our interests really to see that happen. And I think all parties and that's us as the regulator, those that we regulate and the users of audit accounts want to see proposals that support timely resolution of cases. And we hope that stakeholders will agree that our proposals, as set out will do that.
00:10:24:15 - 00:10:28:13
Anthony Barrett
But we'll look at any suggestions or feedback that will help us achieve that goal.
00:10:28:15 - 00:10:50:16
Kate O'Neill
Absolutely. So the messages I've heard for me, both particularly for me, Jamie's pleased to put your responses into an official response to the consultation by January the 9th. And, Anthony, this is part of a number of things going on at the FRC, including the Future of Audit Supervision project, because there are some interlocking pieces that will be important to get right across both projects.
00:10:50:16 - 00:11:05:15
Kate O'Neill
So thank you, Jamie. And Anthony for your time today. And to those listeners out there, please get involved because the clock is ticking and we really want to hear from as many of you as possible on this important consultation. Thanks again and bye for now.