Insolvency Practitioner Regulation Assessment
An assessment of the Wolf position against the framework within which UK insolvency practitioners are regulated. Six limbs, each stating the requirement, the position and how it is evidenced.
First issued 21 January 2026. This edition, IPRA / 2026.01. Third in the series, alongside the Consumer Duty Assessment and the SRA Compliance Assessment.
Wolf builds and maintains infrastructure.
Wolf is not an introducer.
- Builds the platform instance the firm owns outright.
- Maintains the passport receiver and the certificate validator.
- Issues certificates to a published standard and holds the central register against which they are validated.
- Operates the rails across which a business transmits its own file to a firm that business selected.
- Identify any business to any firm.
- Release any record to any firm.
- Make, arrange or procure any introduction.
- Recommend, rank or steer toward any practitioner.
- Advise any director on solvency, insolvency or any procedure.
- Take any appointment or hold any interest in any outcome.
- Receive any payment that depends on an appointment, a realisation or a recovery.
The client decides. The client transmits. Wolf carries.
Why this assessment exists
A practitioner who receives work through any channel remains answerable for that channel. Wolf has therefore assessed its own position against the rules the practitioner works under, rather than leaving the practitioner to do it.
The regulatory framework for insolvency practitioners has tightened materially around advertising, marketing and the use of introducer firms. The Insolvency Service has published strengthened guidance for the recognised professional bodies on monitoring those areas, issued amid concern about the activity of some introducers. The Insolvency Practitioners Association states that it does not recognise the use of non FCA regulated introducers.
Wolf engaged with those requirements before building, not after. The architecture of the platform was set against them: the client selects the firm, the client transmits its own file, no record is released by Wolf, no introduction is made, and nothing Wolf is paid depends on any appointment. Each of those is a design decision taken to sit inside the framework, and each is evidenced on the face of every certificate issued.
Where the framework sets a requirement, this assessment states it, states what Wolf does, and states how that can be tested. Where Wolf goes further than the framework requires, that is stated too, and marked as such.
Who regulates the practitioner
An insolvency practitioner in the United Kingdom is authorised and regulated by one of three recognised professional bodies, each recognised for the purposes of section 391 of the Insolvency Act 1986.
The Insolvency Service is the oversight regulator. The Secretary of State holds a set of oversight sanctions over the recognised bodies, introduced into the Insolvency Act 1986 by the Small Business, Enterprise and Employment Act 2015, and the bodies account to the Insolvency Service for how they supervise their own members. During 2025 the Insolvency Service introduced a data led, risk based approach to monitoring the bodies, with quarterly returns in a consistent format.
This assessment is written against all four, together with the Statements of Insolvency Practice issued through the Joint Insolvency Committee and the Insolvency Code of Ethics.
Six limbs
Each limb opens on click. The requirement is stated first, in the terms the framework uses. The Wolf position follows. The evidence is what a monitor or a compliance officer can test.
A01 Introducer status
The Insolvency Service has published strengthened guidance for the recognised professional bodies on their monitoring of insolvency practitioners' advertising, marketing and use of introducer firms, issued amid concern about the activity of some introducers. The Insolvency Practitioners Association states that it does not recognise the use of non FCA regulated introducers.
Wolf is not an introducer and does not act as one. Wolf identifies no business to any firm, releases no record to any firm, and makes no introduction. A business holding a passport account selects a firm from what is shown in its own account and transmits its own certified passport to that firm. The transmission is the client's act. Wolf operates the infrastructure across which it travels.
- Gate 03 records the client's own instruction to transmit, dated, on the face of the certificate.
- Contact permission and introduction permission are captured as two separate acts, not one combined consent.
- No record leaves the platform by any route other than a client instructed transmission.
- The panel of firms shown to a client discloses that firms hold platform positions, so the basis of what is shown is visible to the client.
Section 2330 of the Insolvency Code of Ethics 2025 addresses agencies and referrals, and the first question a compliance officer asks is who decided which firms are shown. The mechanics are therefore stated in full.
- Entry. A firm appears only where it holds a live Insolv Platform instance and a live maintenance contract. Licence is verified with the authorising body before any account opens.
- Eligibility. Every firm meeting that test is eligible. Wolf applies no further selection, no vetting on commercial grounds and no discretion over who may appear.
- Ordering. Firms are presented in a neutral order that varies between clients. No firm holds a permanent position, no position is bought, and no ordering is derived from what a firm pays.
- No algorithmic matching. No model, score or profile determines which firm any individual client sees. What a firm has paid does not affect the presentation shown to any client.
- No recommendation. Wolf ranks nobody, endorses nobody, and offers no comparison, rating or commentary on any firm. The client is given the identity of eligible firms and nothing more.
- Disclosure. The client is told on the face of the panel that firms hold paid platform positions with Wolf, so the commercial basis is disclosed before any selection is made.
- Equal treatment. Every eligible firm is treated identically, whatever band it holds. A capacity band caps what a firm receives. It never raises what a firm is shown.
- Certain regulatory guidance concerning introducers, lead generators and debt advice arose principally in the individual insolvency market, covering IVAs and protected trust deeds. Wolf operates principally in corporate SME insolvency and does not assert that every provision framed for that market governs the corporate model.
- Wolf nevertheless applies the relevant principles concerning independence, marketing, remuneration, the customer journey and auditability to its corporate infrastructure, because the principles hold whatever the procedure.
A02 Remuneration
The Financial Conduct Authority prohibits remuneration for debt packagers. The recognised professional bodies' joint guidance of October 2025 states that arrangements must not be used in a way that weakens consumer protections or undermines regulatory requirements, including that ban.
Wolf receives no payment that depends on any appointment, any realisation or any recovery. Charges are for infrastructure: the build, the maintenance of the receiver and validator, a capacity ceiling and a metered rate per certified file received. Nothing Wolf is paid rises or falls with what a practitioner decides.
- No revenue share, no contingency and no percentage of any appointment, realisation or recovery, stated in the Master Services Agreement and in every commercial instrument.
- A capacity band is a ceiling on volume received, priced in advance and independent of outcome.
- The metered rate is a price for supply, charged on receipt of a file, not on any subsequent event.
- No sum is payable to any business, director or third party for raising a hand or for selecting any firm.
A03 Advertising and marketing
The Insolvency Code of Ethics 2025, approved by the Joint Insolvency Committee and issued by ICAEW, ICAS and the Insolvency Practitioners Association, came into force on 1 October 2025. Section 2360, advertising, marketing and other promotional activities, requires a practitioner considering an appointment to be satisfied that relevant advertising and marketing is fair, is not misleading, avoids unsubstantiated statements and complies with applicable advertising rules. Where work arrives through a third party, that responsibility extends to the third party. Section 2330 addresses agencies and referrals. The revised Code also introduces duties to safeguard information and to assess the reliability of technology outputs.
Every figure published on any Wolf surface carries its class on the face of the page. Verified means a named publisher, sourced, dated and linked. Reported means a Wolf platform counter, moving continuously and not independently verified. Assessment means an estimate, labelled as one. Nothing is published without a class.
- No claim of government backing, government approval or any scheme endorsement appears on any Wolf surface.
- No claim as to any level of debt write off, any recovery or any outcome appears anywhere.
- No regulator, oversight body or recognised professional body is stated or implied to have reviewed, approved or endorsed the platform or the standard.
- Modelled figures are labelled as modelled, with the base and the date stated.
- Client facing surfaces state plainly that any appointment arises from a licensed practitioner instructed by the client.
A04 The client journey
Insolvency Service guidance identifies a responsible approach to the customer journey as an important part of what practitioners must ensure, including satisfying themselves that correct advice has been given before an introduction is acted on.
The journey is documented end to end and every step is dated. A business completes a structured declaration of its own position, elects separately whether it wishes to be contacted and whether it wishes to be introduced, and selects the firm itself. No step is completed on the client's behalf and no default is preselected.
- The declaration is completed by the director, not by an operator, and the completing person is evidenced as an officer at Gate 02.
- Nothing on the platform advises on solvency, on insolvency, or on any procedure or course of action.
- The client can decline introduction while accepting contact, and the record shows which was elected.
- The certificate carries the issue date, so the practitioner can see when the declaration was made rather than when the file arrived.
- Nothing in any Wolf certificate, output or assessment substitutes for the practitioner's own professional judgement, verification, advice or statutory duties. Wolf provides evidence. The practitioner makes the decision.
- The evidence class map exists so that a practitioner can assess the reliability of what the technology produced, which is what the Insolvency Code of Ethics 2025 now requires of them.
A05 Estate assets and redress
ICAEW, ICAS and the Insolvency Practitioners Association have issued joint interim guidance for office holders on the handling of motor finance redress claims, in place while the challenges to the Financial Conduct Authority scheme continue.
The claim estate module quantifies and evidences. It does not determine, advise or pursue. Every value it produces is an identified value carrying its evidence class, never a realisation and never a forecast of one, and the vesting question is carried as a flag rather than answered.
- Gate 05 requires any claim carried on a file to trace to an evidenced origination before it can be certified.
- Whether a claim vests in an estate, and whether the office holder can pursue it, is stated on every output as a legal question for the practitioner alone.
- Identified value and realisable value are reported as separate figures and are never combined.
- Duplication is tested at Gate 06 so a claim already advanced elsewhere is flagged before an office holder acts on it.
A06 Records and monitoring
Recognised professional bodies monitor their members against the Statements of Insolvency Practice issued through the Joint Insolvency Committee, the Insolvency Code of Ethics and their own rules. The Insolvency Service moved to a data led, risk based approach to monitoring the bodies during 2025, with quarterly returns in a consistent format.
Everything the platform produces is built to be producible on a monitoring visit rather than assembled for one. Records are structured, dated and retained in a form a monitor can read without interpretation, and the evidence class of every field is on the face of the record.
- An exception register runs across the book, so a failure pattern is visible rather than buried in individual files.
- Certified percentage is reported as at a date, never in general, because a declaration is true as at its date and no longer.
- Every certificate is validatable against the central register, so a monitor can test a file independently of the firm holding it.
- The firm is the controller of everything it receives and holds, and its estates are never surfaced to any other firm.
Where Wolf goes further than the framework asks
Compliance is the floor. Four positions below are taken because they are right, not because any rule requires them.
The standing test applied throughout
Every design decision on the platform is tested against one question: would this survive a monitoring visit at the firm receiving it. Anything that would not survive that question does not get built, whatever it would be worth commercially.