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 as part of the wider insolvency objectives of protecting and promoting the public interest, promoting the maximisation of 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 is 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 Joint Insolvency Committee, 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 Joint Insolvency Committee, and WG, are now seeking your views on the proposed changes to SIP 2 and there is an opportunity in the consultation questionnaire to suggest other changes to SIP 2. The questionnaire can be found on the R3 website (linked below).
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 seen relevant to do so, within the body of the SIP.
The intention is to ensure that it is explicit, when deemed necessary (i.e. when proportionate, economic etc.), that the SIP requires an interrogation of information/data (analysis) and not just a gathering in 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 This approach has been favoured to ensure that the SIP is not quickly outdated in the face of the continuing developments in investigative and analytical tools available to the sector (AI etc.) 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 at paragraph 4d) and can see a requirement for reports to be filed to multiple regulators (as at paragraph 29).
Updates to reflect changes since the SIP was last updated.
The WG has sought to update the SIP to ensure that it is 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 within the SIP.
Continued use of “books and records (in whatever form)”
The WG has not sought to amend the wording, or to provide an explanatory note for what is meant by the continued use of the wording, “books and records (in whatever form)”. The WG believes that the continuing 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
A copy of the proposed revised SIP, and consultation document, can be found on the R3 website (linked below) together with the version of the SIP currently in force.
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 twelve weeks, closing on 6 August 2026.
The proposed revised SIP 2 will apply in England and Wales, Scotland and Northern Ireland and will replace the individual SIP 2s which apply in each jurisdiction.
R3’s General Technical Committee, and Scottish Technical Committee will be responding to the consultation on behalf of members. However, if you wish to contribute your views, please email the R3 Technical Team at R3TechnicalTeam@r3.org.uk.
Questions
(1) Do you think the revised SIP identifies all relevant principles and key compliance standards?
(2) Is adding analysis to the SIP’s title and content a useful improvment to the Standard, and does the SIP clearly reflect the intended purpose described above, or is further specificity needed?
(3) Does the continued reference to “books and records (in whatever form)” within SIP 2 adequately encompass the full range of a company’s records, including wider operational and business information such as electronic communications (including emails and messaging applications), contractual documentation, and other non-financial records?
If you believe that it does not continue to be the appropriate wording please confirm:
(i) the reasoning behind you having reached that conclusion; and
(ii) your thoughts on a more adequate wording to cover the full range of a company’s records.
(4) Does the proposed amended SIP sufficiently address any concerns held relating to the key areas of the SIP including investigation, analysis and reporting?
(5) If you feel that there are areas that could be strengthened or added, or alternatively that are surplus to requirements, please expand upon that thinking in your reply.