Consultation on revising Statement of Insolvency Practice 2

14 May 2026

Last updated: 14 May 2026

David Menzies
Director of Practice, ICAS

The Joint Insolvency Committee (JIC) has commenced a consultation exercise on proposed changes to Statement of Insolvency Practice (SIP) 2 – Investigations by office holders in administrations and insolvent liquidations and the submission of conduct reports by office holders.

SIP 2 was last updated in 2016. Since then, investigations by office holders have continued to be a key focus for the Insolvency Service and insolvency recognised professional bodies. This is part of the wider insolvency objectives of promoting public interest, maximising the value of returns to creditors and generally maintaining trust and confidence in the insolvency regimes.

In addition, there have been developments in technology and ways of working since SIP 2 was last reviewed. It’s anticipated that further developments, for example in relation to artificial intelligence (AI) and open banking, will impact the nature of and how investigation work may be carried out by insolvency practitioners.

While the existing SIP 2 is robust, the JIC, through a Working Group (WG), has undertaken a review to ensure that it remains relevant and effective in the current and future landscape. The WG has proposed a revised SIP 2 and the JIC has approved its circulation to the profession and other stakeholders for consultation.

The introduction of specific reference to a requirement for analysis

The headline suggested amendment to the SIP is to include ‘analysis' within the title and, where relevant to do so, within the body of the SIP.

The WG’s intention is to ensure that it’s explicit, when deemed necessary (ie when proportionate, economic etc), that the SIP required an interrogation of information/data (analysis) rather than a gathering in, and non-interrogation, of that data.

The WG’s intent is for the inclusion of analysis within the SIP to be introduced in a non-specific/non-instructive manner. This approach has been favoured to ensure that the SIP is not quickly outdated in the face of the continuing developments in investigative and analytical tools available to the sector (AI, for example) and also to ensure that the analysis requirements remain ones which are ultimately dependent on the specifics of the individual cases (proportionality, economic viability etc).

A more specific emphasis on reporting requirements to regulators

The SIP has sought to make clear that certain reporting requirements can continue after statutory specific timings (as outlined in paragraph 4d) and can see a requirement for reports to be filed to multiple regulators (as outlined in paragraph 29).

Updates to reflect changes since the SIP was last updated

The WG has sought to update the SIP to ensure that it’s accurate at this current time. That has primarily seen updates to the names of regulators but has also seen the addition of practices more common in the sector since the SIP was last updated, including the addition, jurisdiction dependent, of a consideration of an assignment of claim (paragraph 15).

The SIP has also been amended to be easier to read and to flow more naturally between relevant and connected points.

Continued use of “books and records (in whatever form)”

The WG has not sought to amend the wording, or to provide an explanation on what is meant by “books and records (in whatever form)”. The WG believes that the use of “in whatever form” is sufficient to convey that whatever the nature of a company’s records (be they paper based, digital, messaging apps etc) they will be covered by this SIP. The WG feels that to be more specific would open the SIP to quickly becoming outdated.

Consultation

Any revised amended SIP will only be introduced after careful consideration of the responses received and any plan to introduce changes will consider any continuing challenges faced by the insolvency profession.

The consultation period opens on 14 May 2026 and will be open for a period of 12 weeks, closing on 6 August 2026.