Winning introductions from accountants and insolvency practitioners
How referral moves on a UK patch, what the ICAEW, insolvency, SRA and FCA texts require to be disclosed, and how much the field of practitioner firms shifts.
Referral is the one subject on which every banker is an expert and very few have read the rules. The rules are short, and they do not all say what the lunch table believes. So here they are, with a count of how far the field moves, for those who would rather not rely on last year's list.
In short
Introductions from accountants and insolvency practitioners turn on disclosure: ICAEW's Code of Ethics, applying from 1 July 2026, requires explicit written client consent before an accountant keeps a referral commission, with a narrow presumption where the client does not respond, and the Insolvency Code of Ethics, applying from 1 October 2025, bars paying for an insolvency appointment. In the 90 days to 8 November 2026, 254 practitioner firms appeared on 2,037 solvent liquidation notices.
Key takeaways
- ICAEW's Code of Ethics, applying from 1 July 2026, requires explicit written consent for an accountant to keep a referral commission of any amount, with a narrow presumption where the client does not respond.
- The Insolvency Code of Ethics, applying from 1 October 2025, says a practitioner, the firm or an associate shall not pay for the introduction of an insolvency appointment.
- The FCA's guidance, in the September 2026 Handbook, says an introducer relying on the article 15 exemption cannot keep a third party payment through standard terms and conditions.
- Measured on 8 November 2026 across 70 areas, the set of five busiest practitioner firms changed in 66 areas, a median overlap of 0.50, while the single leading firm changed in 12.
- In October 2026, 204 practitioner firms were named on solvent liquidation notices and the ten busiest handled 30.0 per cent of them.
How does referral move on a patch?
For a solvent liquidation, the public record names the professional already in the owner's affairs. The notice names the insolvency practitioner appointed, and in October 2026 only 21 of the 970 notices named no firm, which is why the notices are worth reading from the adviser's side. The accountant who files a company's accounts and the solicitor on a charge may also appear on the record, company by company, though the counts on this page cover practitioners only.
In the house's experience introductions can run both ways, since liquidators and private bankers act for the same kind of owner.
What a banker brings, as the house sees it, is the firm's reputation at first and then introductions going both ways. It helps when both people are at the same stage, building their books.
With a firm you do not yet know, the house advises approaching the person at your own stage rather than the senior partner, and opening with something specific to their client or patch and what you can bring them. That is the house's view and not a statistic.
How much do the practitioner firms on a patch change?
Over one month, the leading firm on a patch mostly holds and the field around it moves. The house compared two 90-day windows of solvent liquidation notices, offset by 30 days, as measured on 8 November 2026, in the 70 postcode areas with enough notices in both windows.
| Measure, two 90-day windows offset by 30 days, measured 8 November 2026 | Result |
|---|---|
| Areas with enough notices in both windows | 70 |
| Median overlap of an area's five busiest firms (1.00 is identical) | 0.50 |
| Areas where the five busiest firms changed in some way | 66 of 70 (94 per cent) |
| Areas where the single leading firm changed | 12 of 70 (17 per cent) |
An overlap of 0.50 between two lists of five, measured on 8 November 2026, falls between three and four firms in common. The two windows measured on 8 November 2026 share 60 days of notices, so the movement comes from one month's turnover in a rolling count, and windows with no days in common could show more. The measure does not span a year, so it says nothing direct about a list kept that long. Areas are set by the company's registered office, which can move to the liquidator's address, so a firm may lead an area partly because it sits there.
The table shows the three firms named on the most distinct notices in the 90 days to 8 November 2026, as each firm's name appears on the notices.
| Firm as named on the notices | Distinct notices, 90 days to 8 November 2026 |
|---|---|
| BTG Begbies Traynor (Central) LLP | 151 |
| FRP Advisory Trading Limited | 113 |
| Leonard Curtis | 103 |
In the same 90 days to 8 November 2026, the 2,037 notices carried 3,187 practitioner appearances from 254 distinct firms. The UK Liquidity Ledger gives the month of October 2026. These counts cover insolvency practitioners on solvent liquidations only.
A list of five that holds its first name and loses a good part of the rest is an awkward thing to keep in a drawer. I mention it only because drawers are where they are usually kept.
What does the ICAEW Code of Ethics say about referral fees and commission?
ICAEW's Code of Ethics, applying from 1 July 2026, treats a referral fee or commission as a self-interest threat and makes retention conditional on the client's explicit written consent. Rule R330.5B covers any fee, commission, payment or benefit received by the accountant or an associate in connection with referring a client, and it applies "regardless of the amount of the commission".
R330.5B offers three routes to consent: an engagement letter clause with examples giving a fair indication of the expected amount, and a prompt letter if the sum is well above them; advance specific written consent; or full written disclosure within a reasonable period after receipt, with a request for consent. If the client does not respond, consent may be presumed only where the accountant can show reasonable efforts to obtain it.
Section 331 bears on where the accountant may send a client. R331.7 says the accountant shall not refer "even with a disclaimer" if they know of a better alternative. R331.8 says a relationship with the third party, such as an automatic referral arrangement, shall be disclosed.
ICAEW's article of 19 October 2022 adds the point most relevant to a private banker. It says ICAEW expects a referral to an independent financial adviser to be the most suitable and objective route for most firms and clients; that a referral to a restricted adviser needs a documented assessment client by client; and that blanket referrals risk a breach of the Code. A banker whose firm gives restricted advice is asking the accountant to carry that assessment.
ICAEW's helpsheet on introductions to financial advisers, reviewed in February 2020, says whether an introduction is regulated depends on the product, the type of adviser and who makes the approach. On its table, a firm's approach to a restricted adviser on securities needs a DPB licence or FCA authorisation. ICAEW's article of 5 February 2024 says a regulated commission cannot rest on general consent in an engagement letter.
How does the Insolvency Code of Ethics bind a practitioner?
The Insolvency Code of Ethics, applying from 1 October 2025, is stricter than the accountants' Code on payment. R2340.4 says an insolvency practitioner, the firm or an associate "shall not make or offer to make any payment or commission for the introduction of an insolvency appointment". The sections read draw no exception for solvent liquidations; a practitioner's regulator is the authority on how they apply.
Receipt is controlled by timing, under the same 2025 Code:
- Before an appointment. Under R2340.5, where an engagement might lead to an appointment, the practitioner shall not accept a referral fee or commission without reducing the threat to an acceptable level. Examples of safeguards include advance disclosure to the appointing body and creditors, and seeking the views of a creditors' committee.
- After receipt, on accepting an appointment. Under R2340.6, the amount and any source of the fee shall be disclosed to creditors.
- During an appointment. Under R2340.7, a referral fee or commission shall not be accepted unless paid into the insolvent estate, and it shall be disclosed to creditors.
Section 2330 of the Code, applying from 1 October 2025, governs referrals with or without money: R2330.5 requires the practitioner to consider the third party's fitness for purpose; R2330.9 bars a referral where a better alternative is known; R2330.10 requires the reasons for recommending a particular provider to be documented; R2330.12 requires a connection with the third party to be disclosed, including any potential benefit, direct or indirect, to the practitioner or others.
When communicating any referral or agency arrangement, application material 2330.11 A3 of the 2025 Code says the practitioner should give the advantages and disadvantages, say that similar services could be available elsewhere at a different cost, state any direct or indirect benefit, and say that independent advice should be considered. The sections read contain no separate rule on an exchange of introductions with no money in it; sections 2330 and 2350 of the 2025 Code, the latter on inducements, are the nearest texts.
Do the SRA rules apply to introductions from solicitors?
The SRA Code of Conduct for Solicitors, in the version in effect from 11 April 2025, applies to a solicitor's referral of a client to another person, and it rests on disclosure and informed consent. Paragraph 5.1 requires clients to be told of any financial or other interest the solicitor, the business or the employer has in referring them, and of any fee sharing arrangement relevant to their matter, and any fee sharing agreement must be in writing. Paragraph 5.3 says a solicitor may refer, recommend or introduce a client to a separate business only where the client has given informed consent. Section 56 of the Legal Aid, Sentencing and Punishment of Offenders Act 2012, read on 8 November 2026, bans referral fees for prescribed legal business, defined around personal injury and death claims and any other description set by regulations. That definition does not describe an ordinary introduction of a solicitor's client to a private bank, where paragraphs 5.1 to 5.3 are the operative text.
What is the FCA position on introducers and financial promotions?
Section 21 of the Financial Services and Markets Act 2000, read on 8 November 2026, says a person must not, in the course of business, communicate an invitation or inducement to engage in investment activity unless the person is authorised or the content is approved or exempt. PERG 8.5.2, last updated in September 2026, says that requires a commercial interest, not necessarily a direct one.
Article 15 of the Financial Promotion Order 2005, read on 8 November 2026, exempts a communication made to introduce the recipient to an authorised or exempt person, on three conditions. The maker is not a close relative or group member of the person introduced. The maker receives no pecuniary reward or other advantage from anyone other than the recipient. And the recipient, as an investor, has not sought advice from the maker, or the maker has declined and recommended an authorised person.
PERG 8.12.11, in the September 2026 Handbook, says the FCA may regard the condition as met where commission belongs to the recipient and is held to their order. In the same September 2026 guidance, the FCA says the introducer "cannot simply tell the recipient" that commission will be received, and that the condition is not met by seeking agreement through standard terms and conditions, or by a mere notice of a sum with a request to keep it.
Article 33 of the Regulated Activities Order, read on 8 November 2026, excludes arrangements for introductions to an authorised person, among others, made with a view to independent advice or the independent exercise of discretion. Legislation.gov.uk, read on 8 November 2026, lists revocation of that Order by the Financial Services and Markets Act 2023 among changes that may come into force at a future date.
The bank's side of the table is governed by COBS 2.3A, which covers MiFID, equivalent third country and optional exemption business and insurance-based investment products, in the Handbook last updated in September 2026. COBS 2.3A.5R applies to paying as well as accepting: a firm must not pay to or accept from any party other than the client a fee or commission in connection with an investment service, unless an exception in COBS 2.3A.6R applies. That exception requires, among other things, that the payment is designed to enhance the quality of the service to the client. Where the firm gives independent advice, restricted advice or portfolio management to a UK retail client, COBS 2.3A.15R separately bars accepting third party fees and commission for that service.
What must a compliant introduction arrangement disclose?
The texts differ on who must be told, what and when. The table summarises each as read on 8 November 2026; whether an arrangement complies is for the firm and its compliance function.
| Text, as read 8 November 2026 | Who must be told | What must be disclosed or obtained | When |
|---|---|---|---|
| ICAEW Code, R330.5B (unregulated commission) | The client | Amount and frequency if relevant, what it was for, how it was calculated, payer and payee; explicit written consent to retain | In advance, or in writing within a reasonable period after receipt |
| ICAEW Code, R331.8 | Not specified in the rule | Any relationship with the third party, including an automatic referral arrangement | Not fixed by the rule |
| ICAEW's account of the DPB Handbook (regulated commission) | The client | Amount and frequency in writing; the right to have it paid over; express written consent to retain | Case by case for each commission |
| Insolvency Code, R2340.6 and R2340.7 | Creditors | Amount and any source of a fee received before appointment; any fee during appointment, which goes to the estate | On accepting the appointment; during it |
| SRA Code, paragraphs 5.1 and 5.3 | The client | Any financial or other interest in the referral; any relevant fee sharing, in writing; informed consent to refer to a separate business | Consent before referring (5.3); timing of 5.1 not fixed |
| Article 15 and PERG 8.12.11 | The recipient | The sum and the right to require it to be paid over, if the introducer is to rely on the exemption while a third party pays | As the guidance describes |
| COBS 2.3A.6R and 2.3A.11R (the regulated firm) | The client | Existence and nature of the payment; the amount or, if unascertainable, the method of calculation, then the exact amount afterwards | Before the service; the exact amount after |
On the texts read on 8 November 2026, the common requirement is that the person each text protects, a client, a recipient or the creditors, can see the money and the connection. No text in the table treats a general line in standard terms as sufficient on its own for a regulated commission or for article 15.
Ask your own compliance function what it wants written down before the first introduction.
Frequently asked questions
Can accountants receive referral fees from financial advisers?
ICAEW's Code of Ethics, applying from 1 July 2026, does not ban a referral commission; R330.5B requires explicit written client consent to keep one, whatever the amount, with a narrow presumption where the client does not respond. The client must be told the amount, what it was for, how it was calculated, and who paid and received it. A regulated introduction has further requirements under the DPB (Investment Business) Handbook, as ICAEW describes them.
Can an insolvency practitioner pay for an introduction?
No, as regards an appointment. R2340.4 of the Insolvency Code of Ethics, applying from 1 October 2025, says a practitioner, the firm or an associate shall not make or offer any payment or commission for the introduction of an insolvency appointment.
Can an insolvency practitioner accept a fee for referring a client to a bank?
Only within limits. Under the 2025 Code, a fee accepted during an appointment must be paid into the insolvent estate and disclosed to creditors (R2340.7). A fee received beforehand must have its threat reduced to an acceptable level, and its amount and any source disclosed to creditors if an appointment follows (R2340.5 and R2340.6).
Is an introducer agreement required by the FCA?
The texts read on 8 November 2026 for this page do not impose a free-standing requirement for an agreement of that name. The tests are whether a communication is a financial promotion and exempt, whether the arrangement falls within an exclusion, and whether a regulated firm's payment meets COBS 2.3A.
Does the leading insolvency firm on a patch change often?
Over one month, not often. Measured on 8 November 2026 across 70 areas, using two 90-day windows offset by 30 days, the single leading firm changed in 12 areas, or 17 per cent, while the set of five busiest firms changed in 66 of the 70, or 94 per cent. The house has no measure across a full year.
Method
Churn is from measure-introducer-churn.ts, run on 8 November 2026: two 90-day windows of Gazette notices under code 2431, offset by 30 days, by postcode area of the company's registered office as held by the house, keeping the 70 areas with enough notices in both windows; overlap is the size of the shared set divided by the combined set. National counts are from measure-report-figures.ts, 90 days to 8 November 2026, by distinct notices. The October 2026 firm count and share are from measure-ledger.ts. Rules are summarised from the primary texts read on 8 November 2026; the DPB (Investment Business) Handbook is reported as ICAEW describes it. This page is market intelligence and is not legal or regulatory advice.
Sources
- ICAEW, Code of Ethics, applying from 1 July 2026, sections 330 and 331, read 8 November 2026: https://www.icaew.com/-/media/corporate/files/technical/ethics/code-of-ethics/icaew-code-of-ethics-2026.ashx
- ICAEW, "Referrals to financial advisers: staying compliant", 19 October 2022, read 8 November 2026: https://www.icaew.com/regulation/regulatory-news/referrals-to-financial-advisers-staying-compliant
- ICAEW, "Referral fees and commissions: client consent is your responsibility", 5 February 2024, read 8 November 2026: https://www.icaew.com/regulation/regulatory-news/regulatory-news-2024-02/referral-fees-and-commissions-client-consent-is-your-responsibility
- ICAEW, helpsheet "Introductions to financial advisers", reviewed 19 February 2020, read 8 November 2026: https://www.icaew.com/technical/tas-helpsheets/ethics/introductions-to-financial-advisers
- Insolvency Code of Ethics, applying from 1 October 2025, sections 2330, 2340 and 2350, read 8 November 2026: https://www.icaew.com/-/media/corporate/files/regulations/insolvency/icaew-insolvency-code-of-ethics-2025.ashx
- Solicitors Regulation Authority, Code of Conduct for Solicitors, RELs, RFLs and RSLs, in effect from 11 April 2025, read 8 November 2026: https://www.sra.org.uk/solicitors/standards-regulations/code-conduct-solicitors/
- Legal Aid, Sentencing and Punishment of Offenders Act 2012, section 56, read 8 November 2026: https://www.legislation.gov.uk/ukpga/2012/10/section/56
- Financial Services and Markets Act 2000, section 21, read 8 November 2026: https://www.legislation.gov.uk/ukpga/2000/8/section/21
- Financial Promotion Order 2005, article 15, read 8 November 2026: https://www.legislation.gov.uk/uksi/2005/1529/article/15
- Regulated Activities Order 2001, article 33, read 8 November 2026: https://www.legislation.gov.uk/uksi/2001/544/article/33
- FCA Handbook, PERG 8.5 and 8.12, last updated September 2026, read 8 November 2026: https://api-handbook.fca.org.uk/files/sourcebook/PERG.pdf
- FCA Handbook, COBS 2.3A, last updated September 2026, read 8 November 2026: https://api-handbook.fca.org.uk/files/sourcebook/COBS.pdf
- The Gazette, notices under code 2431, to 8 November 2026, as held and counted by the house.
Winny is the house’s pen name. This page is written by Windfall Intelligence Ltd from the UK public record, every figure re-measured on the date it carries, and checked by a person before publication. How these pages are made. Corrections to hello@joinwindfall.com.
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