Complaints FAQs

You can check whether your accountant is an ICAS Member by searching for him/her on Find a CA. Alternatively, please call the Investigations Department on +44(0)131 347 0271 and we can check for you.

ICAS Members will usually appoint a person within the Firm with specific responsibility for dealing with client complaints. You should first raise the matter with the individual with whom you have been dealing or a nominated partner within the firm to try to resolve the matter. The Firm is obliged to inform you in writing of your right to bring your complaint to the attention of ICAS. If you are dissatisfied with the outcome of the discussions, and if the individual concerned is an ICAS Member, you can submit a complaint.

If you wish to complain about an Insolvency Practitioner, you will need to submit a complaint to the Insolvency Service in the first instance.

The Insolvency Service, which is part of the Department for Business, Energy and Industrial Strategy, operates a single complaints gateway for all complaints against Insolvency Practitioners practising in Great Britain. If the Insolvency Practitioner in question is licensed by ICAS, your complaint may eventually be referred to ICAS to consider and possibly investigate.

If you have concerns about an Insolvency Practitioner's handling of a case and you have failed to resolve the matter directly, then you should contact the Insolvency Service in the first instance on:

• Telephone: +44 (0)300 678 0015 (call charges may apply)
• Email: ip.complaints@insolvency.gsi.gov.uk

ICAS can investigate complaints against firms which are authorised by us to conduct audit work or to provide investment advice on a smaller scale (referred to as ‘Designated Professional Business’ or ‘DPB’ work). Your complaint may also be directed against the firm if it relates to firm-wide compliance issues (e.g. Anti-Money Laundering, Client Money Regulations) or breaches made by a non-CA principal or senior employee.

Please note that:

• Public interest complaints often fall under the remit of the Financial Reporting Council (FRC) – for example, a complaint relating to the audit of a failed PLC.
• While ICAS has members in the ‘Big Four’ accountancy firms, it does not regulate these firms as entities. This means that a complaint against a Big Four firm would need to be made to the whichever professional body regulates that firm.

It can often be difficult for ICAS to investigate anonymous complaints, as we will not be able to clarify the concerns which have been raised, or get feedback on the Member’s responses to the allegations. We would therefore encourage you to provide your name and contact details when making a complaint.

If a complaint is made anonymously, we may, however, attempt to investigate if the complaint discloses sufficient evidence of concerns, or if we think it is otherwise in the public interest.

For most complaints, it will be preferable for ICAS to disclose the complainer’s identity to the Member under investigation. This is standard practice in most complaint processes, for various reasons:

• it increases the transparency of the investigation;
• it avoids potential issues with regard to Subject Access Requests made under Data Protection
  legislation;
• if the complaint proceeds to a Discipline Tribunal hearing, ICAS will likely have to disclose all
  information and evidence in support of the complaint.

However, we will consider withholding the complainer’s identity if there are good reasons to do so. An example of where this might be appropriate is with whistleblowing complaints, where a complainer wants to disclose concerns involving their employer, but does not want to be exposed to the possible consequences which reporting may bring.

Please note that even if we do withhold the complainer’s identity, it may still be apparent to the Member from the context of the complaint.

Please visit our how to make a complaint webpage to find out how to make a complaint.

ICAS will not consider complaints that involve fee disputes between a Member and a client where the dispute relates to the amount of the fee. This is considered to be a commercial matter. ICAS does not recommend a scale of fees/charge out rates for its Members.

Section 240 of the ICAS Code of Ethics relates to fees and we will only consider complaints that involve a potential breach of these provisions.

If you believe you have suffered financial loss, we would advise you to obtain legal advice. This would be considered a civil matter as the law provides a remedy for professional negligence. Please note that ICAS does not have the power to award compensation or order our Members to award compensation. We can however consider allegations that a Member’s work has fallen short of the expected standards.

ICAS can investigate complaints against firms which are authorised by us to conduct audit work or to provide investment advice on a smaller scale (referred to as ‘Designated Professional Business’ or ‘DPB’ work). Your complaint may also be directed against the firm if it relates to firm-wide compliance issues (e.g. Anti-Money Laundering, Client Money Regulations) or breaches made by a non-CA principal or senior employee.

Please note that:

• Public interest complaints often fall under the remit of the Financial Reporting Council (FRC) – for example, a complaint relating to the audit of a failed PLC.
• While ICAS has members in the ‘Big Four’ accountancy firms, it does not regulate these firms as entities. This means that a complaint against a Big Four firm would need to be made to the whichever professional body regulates that firm.

The timing will depend on the circumstances of the complaint. The Case Officer appointed to consider your complaint must decide whether the issues concerned need to be referred to the Investigation Committee. He or she will aim to make this decision within three months of receipt of your complaint.  Where a complaint is referred to the Investigation Committee and possibly to a Discipline Tribunal, the process can take much longer. The Investigation Committee expects complaints to be concluded within 12 months of receipt.

There will be circumstances where it is possible for a Member and a complainer to resolve a disagreement without the need for ICAS to carry out a formal investigation of a complaint. ICAS refers to complaints resolved in this manner as having been 'conciliated'.

Further information on this process can be found in our Conciliation Guidance. Please contact the Investigations Department on +44(0)131 347 0271 to discuss any questions you may have regarding the process.

There are a number of sanctions that can be imposed on a Member if the complaint is upheld by either the Investigation Committee or a Discipline Tribunal.

Less serious matters may be dealt with by way of a caution. If the conduct concerned is more serious then there is a range of possible outcomes, including financial penalties. In the most serious cases, the Member may be suspended or excluded from Membership.

Full details of the sanctions available can be found in ICAS’ Sanctions Guidance. In nearly all instances, a sanction against a Member will receive publicity.

The professional bodies which authorise Insolvency Practitioners have agreed common sanctions guidance which applies to insolvency-related complaints. This guidance is available here.

If a complaint is upheld, an Adjudication Committee can seek to apply a financial penalty, as set out in the Sanctions Guidance.

The default position is that, if the complaint is upheld, the Member will also be liable for the reasonable costs of an investigation. These costs will include the time spent by ICAS staff in investigating the complaint (which is charged at £140 per hour and recorded in units of 15 minutes, at a rate of £35 per unit). It will also include external costs incurred during the investigation (e.g. Committee costs, the cost of an expert report).

Whilst some cases can be dealt with relatively quickly, more technical or complicated cases will take longer. Costs may be reduced where parties to a complaint respond fully and promptly to requests for information.

Please note that ICAS does not have the power to award compensation to a complainer, or to require a Member or Firm to pay compensation.

The Investigation Committee includes a number of lay members whose participation in the investigative process provides scrutiny of the conduct of those investigations thereby protecting the public interest. If the Committee decides that there is no case for the Member to answer, and if you are dissatisfied, then you are entitled to apply for a review by the Independent Examiner, providing certain criteria are met. The Independent Examiner is neither a Chartered Accountant nor an employee of ICAS.

The Independent Examiner Regulations can be found here.

Whilst there is no Ombudsman, concerns over ICAS’ handling of a complaint may be raised with our oversight regulators. For insolvency complaints please contact the Insolvency Practitioner Review Service at the Insolvency Service on: +44 (0)300 678 0015 and for all other complaints please contact the Professional Oversight team at the Financial Reporting Council (FRC) on: +44 (0)20 7492 2455.

Please refer to our complaints information for ICAS Members webpage if you are the subject of a complaint.

If you would like some general support over the course of the investigation process, you can contact ICAS’ Practice team. Whilst the team cannot give advice on how to respond to complaints, some Members may benefit from the chance to speak to someone in confidence.

ICAS’ Practice team can be contacted on +44 (0)131 347 0249 or at practicesupport@icas.com.

The following helpsheets provide more information on our complaints process:

• General Complaints
• Investigation Stage
• Our Commitment to a Fair Investigation

If you have any questions that are not otherwise answered on this page, please feel free to contact the Investigations Department on +44 (0)131 347 0271.