Insolvency technical update: November 2025

Read our latest insolvency technical update – your round-up of the recent developments in insolvency.

Advance notification of redundancies - HR1

The HR1 form can now be completed and submitted digitally via gov.uk 

From 1 December 2025 paper forms won’t be accepted.

INSSight rollout

An update on the rollout of the new INSSight case management system has been issued by the Insolvency Service, including accessing guidance for IPs on how to use the new templates.

Accountant in Bankruptcy (AiB) organisational changes

The AiB restructured its internal teams from 3 November, impacting personal and corporate insolvency operations. Find out more including new contact email and phone numbers. Firms should ensure that data and contact information in insolvency case management systems is updated.

Court Reporting – Court of Session

We understand that the Court of Session have made procedural changes to the court reporting process. In particular, interlocutors issued will generally no longer include a remit to the Auditor of the Court of Session (the Auditor) and the related order for the Auditor to confer with the reporter.

We understand that the commercial judges have discussed the matter in detail, and their agreed view is that this remit was most often unnecessary. Their view is that, in the normal course, the appointed reporter is to carry out their work as normal and then lodge their finalised report in the normal way. The legal agent for the insolvency office holder can thereafter enrol a motion for the report to be approved and the necessary remuneration sanctioned. 

The commercial judges would then consider the matter on the papers. If they wished the matter to call, or if a remit to the Auditor was deemed necessary at that point, it could be addressed as and when required.

We have recently held discussions with the commercial judges regarding the court reporting process in the Court of Session more generally. We expect to issue an update to the ICAS Court Reporter pack in due course which will incorporate necessary amendments to reflect the procedural changes highlighted above.  

HMRC Insolvency practitioner bulletins

IP Bulletin 9 (2025) provides information about the introduction of a new way for contacting HMRC’s Member Voluntary Liquidation team. 

Use of the guidance will become mandatory but a transition period will be in place until 2 February 2026. After this date, HMRC have advised that any MVL related emails that don’t follow the new guidance process won’t be actioned.

IP Bulletin 5 (2025) – Excise and insolvency - first published in April 2025 has had the links within this bulletin to use to contact HMRC updated.

Suspicious Activity Reporting Best Practice Updates

Revised guidance setting out best practice for Suspicious Activity Reporting has been issued by the UK Financial Intelligence Unit. 

The updated guidance replaces all previous guidance, which is no longer in effect and should now be disregarded.

Firms who are supervised for AML purposes should ensure that their Money Laundering Reporting Officers (MLROs) and Money Laundering Compliance Partners (MLCPs) are aware of and familiar with the revised guidance. Firm policies and procedures should also be reviewed and updated as necessary to take account of the latest guidance. More information is available in this article.

Special administration – T&S administration

The Carbon Dioxide Transport and Storage (Licensed Operators) Administration (England and Wales) Rules 2025 introduce a T&S administration regime, a special insolvency regime specifically created for companies holding licences under section 7 of the Energy Act 2023. The new Rules and special administration regime came into force on 19 November 2025.

Changes to insolvency practitioner bonding regime in Northern Ireland

The Insolvency Practitioners (Amendment and Transitional Provisions) Regulations (Northern Ireland) 2025 brings in changes to IP bonding for Northern Ireland. The new bonding provisions will be introduced during a transitional period from 9 December 2025 to 31 December 2026 and be fully effective from 1 Jan 2027. The changes reflect the changes to IP bonding in England and Wales and Scotland which are currently in a transitional period and become fully effective on 1 January 2026.

Legal update

Rawbank SA v Banfield & Ors (Re Travelex Bank Notes Ltd) [2025] EWHC 3054 The High Court considered and granted an application for additional liquidators to be appointed to investigate potential claims, citing concerns over conflict of interest with the current liquidators. (via Enterprise Chambers)