Accountancy regulators confront AI cheating in exams

The Association of Chartered Certified Accountants (ACCA) has confirmed that from March 2026, most exams will return to in-person settings. Remote assessments will only be permitted in exceptional circumstances, such as medical needs or where no exam centre is available. This change reverses the flexibility introduced during the Covid-19 pandemic.
 

The decision follows mounting concerns about exam integrity. ACCA’s Chief Executive, Helen Brand, explained that cheating methods have become increasingly sophisticated, outpacing the safeguards currently in place. The rapid rise of artificial intelligence (AI) tools has pushed the issue to what ACCA describes as a “tipping point,” making remote invigilation too difficult to police effectively.

Regulatory context
 

The Financial Reporting Council (FRC) has previously described cheating in professional exams as a “live issue,” noting misconduct among major firms, including the Big Four. In 2022, EY agreed to pay a record $100m fine to US regulators after employees were found to have cheated on ethics exams and misled investigators.

Other UK bodies face similar challenges. The Institute of Chartered Accountants in England and Wales (ICAEW) still permits some exams to be taken online but acknowledges that very few high-stakes assessments now rely on remote invigilation. ICAEW has also highlighted the need to monitor AI risks closely.

The Association of Taxation Technicians (ATT) has taken a different approach by introducing explicit rules banning the use of AI tools during online exams. Its updated regulations require webcam monitoring and instrument checks, with strict penalties, including disqualification, for violations. This reflects a growing trend among UK regulators to tighten controls on technology use during assessments.

Greater scrutiny on exam conduct
 

Cheating in professional exams has become a clear area of regulatory focus with the risks introduced by AI. Firms are under increasing pressure to ensure their trainees uphold the highest standards, as any breach can have serious consequences for both the individual and the organisation. Individuals sitting these exams must take care to comply fully with all requirements.

Failing to meet these expectations can result in disciplinary action, reputational harm and, in serious cases, removal from the profession. Such behaviour may breach key elements of the ACCA’s Fundamental Principles of Ethics. ACCA emphasises the importance of acting with integrity across all aspects of qualification, including exams, the Ethics and Professional Skills Module and the Practical Experience Requirement. Students are expected to demonstrate honesty, fairness, respect, responsibility and courage. By registering as a student, individuals commit to following ACCA’s rulebook, upholding its ethical standards and complying with all exam regulations and guidance. Given the seriousness of these obligations, it is essential that candidates approach the exams with care and diligence.

Candidates who cannot attend in-person exams should raise this early and provide supporting documentation. Firms should actively remind trainees of their obligations and implement measures to reinforce compliance.  

Firms also have a responsibility to remain vigilant by regularly reviewing and strengthening their internal controls to detect and prevent exam-related misconduct. This includes reflecting on the organisation’s broader culture and identifying any systemic risks that could undermine a commitment to integrity at all levels; not just among junior staff. These efforts should sit within a wider corporate and regulatory framework that promotes the ethical and responsible use of AI across the firm.

Considerations for the future of exam regulation
 

This shift raises important questions for the future of exam regulation in the accountancy sector:

• Are in-person exams financially sustainable in the long term, given the costs of exam centres, invigilators and logistics?
• Can technology ever guarantee the integrity of remote exams? Current remote invigilator tools use biometric checks and AI-driven monitoring, but these measures have limits as cheating methods evolve.
• How should regulators balance security with accessibility and cost? Remote exams offer convenience for candidates in remote areas or with disabilities, but they also introduce significant risks to credibility.

These issues are being actively debated across the profession. Regulators will need to ensure that they keep on top of monitoring the use of AI. The FRC will continue to scrutinise how firms and professional bodies manage exam integrity, and whether their systems and oversight remain fit for purpose.

Future outlook
 

At present, it appears regulators are struggling to keep pace with rapid AI developments. As a result, the profession is reverting to traditional methods that offer greater credibility and trust. However, this approach raises the question: how sustainable is it in the long term? At some point, regulators will need to identify a financially viable solution that combines robust security with practical delivery.

In the meantime, firms and individuals should keep up to date with any changes in their regulator’s rules on exam conduct to ensure full compliance. Firms, and indeed those aspiring to join the profession, must recognise their ongoing responsibility to uphold integrity and the highest standards of professional behaviour. This obligation does not diminish simply because new technologies emerge or because regulators face challenges in keeping pace with them.

If you have any questions about complying with exam regulations, or if you are facing an investigation for an alleged breach, please contact our Regulatory team at Kinglsey Napley.

About the authors

Zoe is an Associate in the Regulatory team, advising regulated professionals and firms on regulatory compliance, professional ethics, internal investigations and disciplinary proceedings.

Ian is a Senior Associate in the Regulatory team, qualified in New Zealand and New York. He specialises in acting for firms and individuals facing regulatory and professional disciplinary investigations. He also provides advice to national regulators across a number of sectors, and regularly represents clients involved in public inquiries and reviews.