Changes to the ICAS Code of Ethics – what do the changes mean for ICAS members

For many chartered accountants, the ethical obligations that come with membership have traditionally been understood through the lens of financial propriety. The issues that have historically dominated the conversation around professional ethics in the accountancy sector have been conflicts of interest, independence, or objectivity in client work.
 

That conversation is changing. Regulators across the profession are increasingly focused on non-financial misconduct, and the standards expected of chartered accountants in how they treat others are now receiving the same serious attention as the standards applied to their technical work. The 2026 updates to the ICAS Code of Ethics reflect that shift, and all ICAS members should be aware of what the changes mean in practice.

A “career for life”

ICAS describes membership not merely as a professional qualification but as "a career for life". The obligations that come with being a chartered accountant do not begin and end at the office door, and they do not diminish once the qualification is obtained. As the ICAS Code of Ethics makes clear, every chartered accountant bears individual responsibility for maintaining the highest standards of ethical behaviour throughout their career, safeguarding not only their own reputation but also that of their organisation and the profession, to the benefit of the public in general.

 

The changes: what has been added and why

With effect from 1 July 2026, the ICAS Code of Ethics incorporates new wording at paragraph 115.1 A2 in relation to the fundamental principle of professional behaviour. The new paragraph reads as follows:

"A reasonable and informed third party would expect that a professional accountant, in their professional life, treats others fairly, with respect and dignity and, for example, does not bully, harass, victimise, or unfairly discriminate against others."

The paragraph was originally developed by ICAEW and adopted into the ICAEW Code with effect from 1 July 2025, following a consultation process to which ICAS responded. It has now been incorporated into the ICAS Code to assist with consistency between the two professional bodies. The direction of travel across the chartered accountancy profession is therefore aligned, with both bodies now setting out the same explicit standard in relation to how members are expected to treat others in their professional lives.

It is important to be clear about what this change does and does not do. It does not alter the substance of the Code. The principle of professional behaviour, and the obligation to avoid conduct that might discredit the profession, has always been part of the framework. What the new paragraph does is make explicit the standard that members are expected to meet when it comes to how they treat others.

 

What "professional life" means in practice

The new paragraph applies to conduct in a member's "professional life", but that concept is considerably broader than it might initially appear. It is not limited to conduct during working hours or within the office environment. “Professional life” encompasses a wide range of contexts where there is some connection to a member's professional role or identity.

A member’s professional life includes conduct at work social events, even where those events take place outside normal working hours or away from the workplace. It covers less formal gatherings with colleagues, attendance at external conferences, and any situation where the member is identifiable as a chartered accountant or is representing their employer or the profession. The key question is whether there is a professional connection, not whether the conduct occurred in a strictly work-related setting.

The practical implication is significant. A member who behaves inappropriately at a firm social event, makes offensive remarks to a colleague during a business trip, or posts discriminatory content on a social media account that identifies them as a chartered accountant may find that their conduct falls squarely within the scope of paragraph 115.1 A2, even if they considered themselves to be acting in a personal capacity at the time.

Personal life, by contrast, covers conduct that is genuinely unrelated to a member's professional role, such as private family relationships, activities during personal time with no professional context, and social media activity where the member's professional identity is not apparent. However, even conduct in a member’s personal life is not entirely beyond the reach of the Code. Where conduct is sufficiently serious, it can still bring discredit to the profession regardless of the context in which it occurred. Criminal convictions are the clearest example of this.

 

The standard against which conduct is assessed

Conduct under the updated Code is assessed against the “reasonable and informed third party” test. This is not a question of whether the member themselves considers their conduct to have been appropriate, or whether they intended any harm. The question is whether a reasonable and informed third party, possessing the relevant knowledge and experience to evaluate the conduct objectively and impartially, would be likely to conclude that it brings discredit to the profession.

The stronger the link between a member's conduct and their professional role, the greater the likelihood that the behaviour will be found to bring discredit to the profession. This is why conduct involving colleagues, clients, or professional contacts is treated more seriously than equivalent conduct in a purely private setting.

 

What kinds of behaviour are in scope

The behaviours explicitly captured by paragraph 115.1 A2 are bullying, harassment, victimisation, and unfair discrimination. These are not defined narrowly, and members should not assume that conduct must reach a particular legal threshold before it becomes a regulatory concern. We set out some examples below.

• Bullying can include spreading malicious rumours, regularly undermining a colleague, unreasonably denying training or promotion opportunities, and other conduct that creates a hostile or demeaning environment.
• Harassment covers unwanted conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, humiliating, or offensive environment.
• Victimisation occurs where someone is treated less favourably because they have raised, or are thought to have raised, a complaint or concern.
• Unfair discrimination covers treating someone less favourably because of a protected characteristic such as age, sex, race, or disability.

It is worth noting that these behaviours need not be deliberate or sustained to attract regulatory attention. A single incident can be sufficient if it is serious enough. The ICAEW case studies, which provide a useful illustration of the types of conduct that regulators are likely to take an interest in, include scenarios involving a one-off incident of sexual harassment during a business trip, offensive social media posts made over a period of time, and a series of aggressive and abusive emails sent to former colleagues. Although these examples were developed in the ICAEW context, they reflect the same standards now incorporated into the ICAS Code, and ICAS members should read them with that in mind.

 

The duty to report

The 2026 changes do not introduce a new reporting obligation, but they sit alongside an existing duty that all members should be aware of. Members have a duty to report any facts or matters which, in their reasonable opinion, indicate that another member, CA student member, affiliate or firm may be liable to disciplinary action. This duty applies to all members, not only those in senior positions.

The strengthened framework around professional behaviour makes this duty more relevant than it may previously have seemed. A member who witnesses conduct by a colleague that falls within the scope of paragraph 115.1 A2 should consider carefully whether a reporting obligation arises. The fact that the conduct occurred at a social event, or that the colleague is a friend, does not remove that obligation.

Members who are uncertain about whether a reporting obligation arises in a particular situation should seek guidance.

 

What this means for members
 

The profession's expectations around how members treat others are now more explicitly articulated than at any previous point, and the regulatory appetite for pursuing conduct matters of this kind is growing. Both ICAS and ICAEW have incorporated this material into their respective Codes, reflecting a shared view that behavioural standards in professional life warrant the same rigorous attention as technical and financial standards.

Members should take the opportunity to reflect on their own conduct across all professional settings, including those that might not immediately feel like "work", and to consider whether it meets the standard that a reasonable and informed third party would expect.

If a complaint is made or an investigation is commenced, the way in which the matter is handled at the outset can shape its entire trajectory. Early legal advice, taken before responding formally to any letter from a regulator, is vital to allow the best chance of a favourable outcome.

At Kingsley Napley, we advise members of professional bodies on regulatory and disciplinary matters, including conduct investigations and proceedings before professional tribunals. If you would like to discuss any concerns in confidence, please do not hesitate to contact us.

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.

Jenny is a Legal Director in the Regulatory Team. She specialises in actuarial, accountancy and financial services regulation, and is experienced in advising regulated individuals and firms as well as acting on behalf of professional regulatory bodies.