The Insolvency Service’s latest enforcement figures show that director disqualification remains an active and substantial risk for directors of insolvent or dissolved companies, particularly where Covid-support, HMRC debts or wider conduct issues are involved.
The April 2026 figures are striking.
- They record 102 director disqualifications in one month, with an average disqualification period of 8 years.
- Of those, 92 were section 6 disqualifications, meaning they related to alleged unfit conduct in connection with an insolvent or dissolved company.
- The figures also show that 64 section 6 cases involved Covid-19 financial support scheme abuse allegations, with an average ban of 9.4 years.
For directors, those numbers matter. They show that the Insolvency Service is continuing to pursue historic conduct, including decisions made during the pandemic and in the period before insolvency. However, an investigation does not mean that disqualification is inevitable. Many directors are contacted because their company has entered liquidation, administration or dissolution, not because wrongdoing has already been established.
What do the April 2026 enforcement figures show?
The April 2026 data shows a significant level of enforcement activity in a single month.
- The headline figure is 102 director disqualifications across Great Britain. The mean length of those disqualifications was 8 years, which is a substantial restriction on a director’s ability to manage, promote or be involved in the running of a company.
- The figures also show that 92 of the 102 disqualifications were made under section 6 of the Company Directors Disqualification Act 1986. Section 6 cases are particularly relevant for directors of insolvent or dissolved companies because they focus on alleged unfit conduct connected with the company’s failure or dissolution.
- Within those section 6 cases, 64 involved allegations relating to Covid-19 financial support scheme abuse. That means Covid-related allegations accounted for a large proportion of the month’s section 6 outcomes. The average disqualification period in those Covid-related cases was 9.4 years, which is higher than the overall monthly average.
- The same data also records 6 section 6 disqualifications involving allegations of unfair treatment of the Crown, showing continued scrutiny of how directors dealt with HMRC and other public debts before insolvency.
Why are Covid-support cases still leading to director disqualification?
Covid-support cases remain prominent because the Insolvency Service continues to review the conduct of directors where companies received public support and later became insolvent or were dissolved.
- A director disqualification investigation may consider whether support was applied for properly, whether the company was entitled to the funds, how the money was used and whether the company’s records support the director’s explanation.
- That scrutiny can extend beyond the original application. The Insolvency Service may also look at what happened after the funds were received, including whether they were used for legitimate business purposes, whether company records were properly maintained and whether payments to directors, connected parties or selected creditors require explanation.
- For directors, this is often a records issue as much as a conduct issue. Decisions made during periods of financial pressure can be difficult to reconstruct years later unless the company retained clear evidence of what was known, what was discussed and why a particular course was taken.
A director who continued trading while HMRC arrears increased, or who made payments to connected parties while tax debts remained unpaid, may face questions about the reasoning behind those decisions. That does not mean the director has no answer. It means the explanation needs to be clear, evidenced and consistent.
What does a director disqualification investigation involve?
A director disqualification investigation is an investigation into a director’s conduct. It is not the same as a finding that the director has acted improperly.
The Insolvency Service may look at
- the period before insolvency,
- the company’s accounting records,
- creditor treatment,
- tax arrears,
- director loan accounts,
- Covid-support applications,
- asset disposals; and
- the director’s cooperation with the office-holder.
The latest data also shows the size of the enforcement pipeline. As at 30 April 2026, the Insolvency Service recorded 1,064 company cases under civil disqualification investigation. It also recorded 206 cases under criminal investigation, 58 live companies under investigation and 38 bankruptcy restriction defendants under investigation.
Those figures are important because they show that enforcement activity is not limited to completed cases. There remains a substantial number of investigations moving through the system. Some will not result in action, but directors should not assume that silence after liquidation or dissolution means the risk has passed.
For directors, the practical message is clear. If the Insolvency Service makes contact, the response should be treated as part of a formal risk process, not as routine administration.
How can directors protect their position if the Insolvency Service makes contact?
The most important step is to avoid treating correspondence from the Insolvency Service as a formality. Directors are often asked to explain decisions made during a pressured period, sometimes many months or years earlier.
A rushed or incomplete response can cause avoidable difficulty later. We see this issue a lot in out team – answers written in haste (often with the best of intentions) can come back to bite later on.
Directors should gather the relevant company records, bank statements, board communications, accountant correspondence, tax records and evidence showing why particular decisions were made. Where Covid-support is involved, the application basis and use of funds should be checked carefully against the company’s circumstances at the time. We are experts in defending director disqualification bounce back claims.
It is also important to distinguish between commercial failure and misconduct. A company can fail for legitimate reasons. Director disqualification is concerned with unfit conduct, not simply with a business becoming insolvent.
Where the Insolvency Service raises concerns, directors may need advice on whether to respond, what documents to provide, whether to offer representations, and whether any proposed undertaking should be resisted, negotiated or accepted.
What should directors take from the latest enforcement data?
The latest enforcement data shows three important points.
- First, director disqualification remains a live and active enforcement tool. 102 disqualifications in April 2026 alone is a clear indication that the Insolvency Service is continuing to pursue director conduct following insolvency and dissolution.
- Second, Covid-support cases remain prominent. Although the pandemic support schemes are now historic, the April 2026 data shows that allegations connected with those schemes are still producing lengthy disqualification outcomes.
- Third, the enforcement pipeline remains substantial. With 1,064 civil disqualification investigations recorded at the end of April 2026, directors should assume that conduct before insolvency may still be reviewed carefully, especially where company records, creditor treatment, HMRC arrears or public support funds are involved.
The key point is not that every investigation leads to disqualification. It does not. The key point is that directors need to respond carefully, preserve evidence and avoid making unsupported explanations or unnecessary admissions.
The Insolvency Service also recorded 4 civil compensation order outcomes and undertakings in April 2026, with a total value of £187,151. That matters because disqualification is not always the only possible consequence. In some cases, financial compensation may also become an issue.
Directors who are contacted after liquidation, administration or dissolution should take the opportunity to understand the case being put against them and respond in a structured way. Early advice can help protect the director’s position, identify weaknesses in the allegations and reduce the risk of avoidable escalation.
Our team at FWJ has been defending disqualification claims for nearly 25 years with outstanding success. There is little we haven’t seen. Contact us today for your free consultation.
Absolutely excellent advice, service, professionalism and most importantly RESULTS! A sensitive case regarding disqualification was bought by the Secretary of State. After failed attempts with previous solicitor, FWJ literally saved the day and was able to secure a win for us. Highly recommended
A client facing a director disqualification
