The Insolvency Service’s enforcement figures for 2025/26 (published 26th July 2026) show that director conduct remains a significant area of regulatory scrutiny. The official figures record 1,158 director disqualifications, alongside criminal convictions, compensation outcomes and public interest winding-up orders.
For directors who have received an Insolvency Service letter or questionnaire, it is important to keep these figures in perspective. It is not unusual for directors of insolvent or dissolved companies to face enquiries, and being contacted does not automatically mean that misconduct has occurred. There are recognised steps directors can take to understand the allegations, preserve relevant evidence and provide a properly considered response.
The published figures cover different geographical areas depending on the type of enforcement action. The director disqualification figures relate to Great Britain, bankruptcy restrictions relate to England and Wales, and public interest winding-up figures are reported on a United Kingdom basis. This article considers the practical position for directors and companies in England and Wales.
What do the Insolvency Service enforcement outcomes for 2025/26 show?
The Insolvency Service enforcement outcomes for 2025/26 record 1,158 director disqualifications resulting from enforcement activity under sections 2, 6 and 8 of the Company Directors Disqualification Act 1986. The average disqualification period was 8.1 years.
Director disqualification is a legal restriction that prevents a person from acting as a company director or becoming directly or indirectly involved in the formation, promotion or management of a company during the disqualification period, unless the court gives permission.
The monthly figures fluctuated during the year.
- March 2026 recorded the highest number, with 128 disqualifications, followed by February 2026 with 116.
- The figures do not explain why activity was higher in particular months, so no firm conclusion should be drawn from the monthly variation alone.
Directors should also remember that director disqualification does not necessarily require a fully contested trial. A case may conclude through a court order or a disqualification undertaking. Anyone considering an undertaking should first understand the proposed allegations, the length of the suggested restriction and the wider effect on their business activities.
Our director disqualification guide explains how an investigation can progress and the practical consequences of an order or undertaking.
Why do COVID-19 financial support cases remain prominent?
Of the 1,158 total disqualifications, 1,044 were made under section 6 of the Company Directors Disqualification Act 1986. Section 6 applies where a person has been a director of an insolvent or dissolved company and their conduct is considered to make them unfit to be concerned in company management.
The Insolvency Service recorded that 773 of the section 6 disqualifications involved at least one allegation relating to abuse of a COVID-19 and bounce back financial support scheme.
- This amounts to approximately 74 per cent of the section 6 total.
- The average disqualification period in cases involving such allegations was 9.4 years, compared with the overall average of 8.1 years.
These figures must be described carefully. The publication records cases involving allegations entered on the Insolvency Service’s administrative systems. It does not provide the underlying evidence, identify the particular support scheme involved in each case or explain whether every allegation was admitted or determined by a court.
The figures also record 119 section 6 disqualifications involving allegations of unfair treatment of the Crown. This category may include conduct concerning unpaid tax liabilities, although the publication does not provide a breakdown of the individual allegations or the circumstances of each company. Only three section 6 disqualifications were recorded as relating to dissolved companies.
A director facing questions about a Bounce Back Loan or another support scheme should not assume that an adverse outcome is inevitable. The appropriate response will depend on matters such as how the funds were obtained, what information was supplied, how the money was used, the company’s financial position and the records available to support the director’s explanation.
What other enforcement outcomes were recorded?
The publication shows that the Insolvency Service’s work extends beyond director disqualification.
In England and Wales,
- 93 bankruptcy and debt relief restrictions were recorded during 2025/26, with an average restriction period of 8.1 years.
- Of those outcomes, 55 involved allegations concerning COVID-19 financial support scheme abuse.
- The criminal enforcement tables record 81 convicted defendants following Insolvency Service investigations and charges. Thirty-one of those defendants were connected with COVID-19 financial support scheme abuse. Sentencing outcomes included 5,705 hours of unpaid work, confiscation orders worth £1,901,579 and a combined 1,304 months of imprisonment, including suspended sentences.
- The civil enforcement figures record 125 compensation orders and undertakings with a reported total value of £4,548,018. The Insolvency Service notes that compensation values may be revised upwards because of delays in recording information on its administrative systems.
- The publication also records 52 companies wound up in the public interest following live company investigations. A public interest winding-up petition is different from a conventional creditor petition. It is normally brought following an official investigation into a company’s activities and can expose directors to further investigation after a winding-up order is made.
These different outcomes can overlap. The existence or absence of a disqualification order does not prevent separate civil or criminal proceedings from being considered. Directors may therefore need to assess not only the immediate disqualification risk, but also possible compensation claims, insolvency claims or criminal allegations arising from the same underlying conduct.
What does the investigation pipeline mean for company directors?
The number of investigations in progress suggests that director conduct will remain an active area of enforcement.
During 2025/26, the Insolvency Service targeted 2,235 companies for civil investigation, 199 cases for criminal investigation and 273 companies for live company investigation. It also targeted 78 bankruptcy restriction cases for investigation.
As at 31 March 2026, there were 1,177 company cases under civil disqualification investigation, 197 cases under criminal investigation and 59 live companies under investigation. During the financial year, the Insolvency Service concluded 1,148 civil director disqualification investigations, 117 criminal case investigations and 185 live company investigations.
These figures do not mean that every investigation resulted, or will result, in enforcement action. The publication does not state how many concluded investigations were closed without further action. It should therefore not be assumed that an investigation automatically leads to disqualification or another adverse outcome.
However, the figures demonstrate why the early stages of an investigation matter. Initial questionnaires, correspondence and supporting documents may shape how the Insolvency Service understands the company’s affairs and the director’s decisions.
Our guidance on responding to an Insolvency Service director investigation explains the issues investigators may examine and how directors can prepare a clear, evidence-based account of what happened.
What should a director do if contacted by the Insolvency Service?
Receiving a letter from the Insolvency Service does not establish that a director has acted improperly. It does, however, require a careful and proportionate response.
- The director should first identify the company, conduct and period under investigation. The precise wording of the allegations matters. A general concern about company failure is different from a specific allegation involving accounting records, tax liabilities, company assets or financial support funding.
- Relevant company records should then be preserved and reviewed. These may include board minutes, management accounts, bank statements, correspondence with accountants, loan applications and evidence showing how company funds were used. A director should not guess where their recollection is incomplete. It is usually better to identify the available evidence and explain any genuine limits on memory.
- Any response should distinguish between decisions made personally by the director, decisions made collectively by the board and matters handled by other employees or professional advisers. Responsibility cannot automatically be transferred to an adviser, but evidence of the advice requested and received may be important when explaining why a decision was made.
- Directors should also consider whether the investigation creates wider risks. Allegations about the use of company money may later be relevant to a misfeasance claim against a director, while issues concerning a live company may develop into public interest winding-up proceedings.
Early legal advice from our director defence team can help a director understand the questions being asked, obtain relevant documents and prepare a response that is accurate without making unnecessary admissions. The objective is not to obstruct a legitimate investigation. It is to ensure that the director’s position is explained fairly, consistently and with the benefit of the available evidence.
How we can help you
Francis Wilks & Jones advises directors at every stage of the disqualification process, from initial Insolvency Service enquiries through to undertakings, court proceedings and applications for permission to act. If you have received an investigation letter or questionnaire, our team can review the correspondence and help you decide on the appropriate next step.
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