As a junior accountant, you are likely already comfortable with the core technical principles that support your role. Much of your day-to-day work is shaped by financial reporting obligations and the need to comply with accounting standards. These are the expectations most junior accountants encounter early in their careers, and many develop a practical understanding of them as they gain experience.
What tends to receive less attention are the regulatory requirements around professional conduct and behaviour. These are not only about getting the numbers right or complying with accounting standards. They also concern how you conduct yourself, how you treat colleagues and clients, and, in some circumstances, how you behave in your personal life. For junior accountants entering the profession today, understanding this aspect of regulation is more important than ever.
As a regulated professional, you are held to higher standards of behaviour than your counterparts in non-regulated industries. The ICAEW Code of Ethics is explicit on this point: chartered accountants are expected to exhibit higher standards of behaviour than ordinary members of the public. This applies not only to your technical work but also to your conduct more broadly.
That is a significant obligation, and one that many junior accountants may not fully appreciate when they first enter the profession. It means that conduct which might pass without comment in another workplace can, in the accountancy context, attract regulatory scrutiny.
The 2025 changes: a strengthened framework
In July 2025, the ICAEW Code of Ethics was updated with significant changes to the professional behaviour principle. The revised Code now explicitly states that “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.”
This update was introduced to strengthen members’ understanding of their professional conduct obligations and to address concerns raised through complaints about poor behaviour. These obligations are not entirely new. The ICAEW has long taken conduct matters seriously, and the 2025 changes represent a further development of an existing framework rather than a departure from it. For junior accountants entering the profession now, however, this means facing a level of scrutiny that is arguably greater than that experienced by many senior colleagues when they began their careers.
As the updated Code only came into effect in July 2025, there are currently few regulatory decisions or tribunal cases arising from these new provisions. Regulatory proceedings often take years to conclude, meaning the profession is currently operating in a period of genuine uncertainty about how these strengthened rules will be interpreted and applied. Junior accountants are therefore navigating enhanced obligations without the benefit of an established body of case law.
Other accountancy regulators are also moving in the same direction. The 2026 ICAS Code of Ethics has been revised to incorporate the application material developed by the ICAEW in relation to the professional behaviour principle, taking effect from 1 July 2026. This followed an ICAEW consultation process to which ICAS responded. The direction of travel across the profession is therefore clear: regulators are placing greater emphasis on behavioural standards, and junior accountants qualifying under either body will face similarly heightened expectations.
What does “professional behaviour” actually mean?
The ICAEW Code of Ethics is built on five fundamental principles: integrity, objectivity, professional competence and due care, confidentiality, and professional behaviour. It is this fifth principle that is the focus of this series, and its scope is broader than many junior accountants realise.
The Code requires members to comply with relevant laws and regulations and to avoid any conduct that they know, or ought reasonably to know, might discredit the profession. This obligation applies “in all professional and business activities whether carried out with or without reward and in other circumstances where to fail to do so would bring discredit to the profession.”
In practical terms, this means that obligations extend beyond paid work. They cover professional life more broadly and, in some circumstances, conduct in a member’s personal life can also be caught if it is sufficiently serious to bring discredit to the profession.
Professional life vs personal life
The Code distinguishes between professional life and personal life, although the boundary between the two is not always straightforward. Conduct will generally be treated as occurring within a member’s professional life if it arises in contexts connected to work or professional activities, including:
- social events or private settings involving colleagues or clients, even away from the office;
- situations where the member identifies themselves as an accountant or publicly represents the profession or their employer;
- external conferences or networking events; and
- social media activity where professional status is visible or identifiable.
The scope of professional life therefore extends well beyond office premises and normal working hours. A work dinner, networking event or LinkedIn profile identifying you as an ACA student would all generally fall within this definition.
Personal life, by contrast, generally includes conduct unrelated to a member’s professional role or obligations, such as:
- personal relationships and interactions with family and friends;
- activities undertaken entirely in a private capacity;
- social media posts where professional identity is not apparent; and
- private social events without professional connections.
However, even conduct in a member’s personal life can bring discredit to the profession if it is sufficiently serious and incompatible with the higher standards expected of chartered accountants. Criminal convictions, for example, may attract regulatory scrutiny regardless of whether they arise in a professional or personal context.
The reasonable and informed third party test
The test for determining whether conduct crosses the regulatory threshold is whether a reasonable and informed third party would conclude that it brings discredit to the member, the ICAEW or the profession. This hypothetical observer is assumed to possess sufficient knowledge and experience to assess the conduct objectively and impartially, taking into account the relevant context.
The underlying principle is straightforward: the stronger the connection between the conduct and the member’s professional role, the greater the likelihood that it could bring discredit to the profession.
What kinds of behaviour are in scope?
The updated Code specifically identifies bullying, harassment, victimisation and unfair discrimination in a member’s professional life as behaviour falling below the required standard. More generally, unprofessional conduct may include:
- bullying and offensive behaviour;
- physical or verbal abuse towards colleagues, clients or others;
- inappropriate sexual conduct; and
- discriminatory comments or behaviour.
To illustrate the types of conduct that may attract regulatory attention, the ICAEW has published case studies based on representative scenarios commonly encountered in conduct reports. Examples include:
- Inappropriate social media use: an accountant making inflammatory or discriminatory comments on a public personal social media account where their professional status is identifiable.
- Rude emails to colleagues: a manager sending aggressive emails to team members and, after leaving the firm, sending an email containing offensive language to a former supervisor.
The ICAEW case studies also include a scenario involving conduct on a business trip abroad, where a partner made unwanted sexual advances towards a junior colleague during a work dinner before later joking about the incident in front of colleagues. The Conduct Committee rejected the argument that the behaviour fell outside the Code because it occurred outside office premises and working hours. Instead, it concluded that the business-trip context, together with the ongoing professional relationship between those involved, was sufficient to bring the conduct within the member’s professional life.
A similar conclusion was reached in a real-world case in 2021, when the ICAEW severely reprimanded and fined a partner at a Big Four firm for inappropriate conduct towards a trainee during a work ski trip. Although the trip was not formally organised by the firm, the ICAEW found that comments made to, and in the presence of, colleagues were capable of bringing both the individual and the profession into disrepute. This demonstrates that the ICAEW assesses conduct by reference to its wider professional context. It is not enough to argue that behaviour falls outside the Code simply because it occurred away from the office or outside normal working hours.
A regulated accountant’s responsibilities
All regulated accountants understand that they must comply with their regulator’s Code of Ethics. However, societal expectations about appropriate and professional behaviour continue to evolve. Conduct that may once have attracted little attention can now be viewed very differently, and the line between acceptable and unacceptable behaviour is not always obvious.
In addition to managing their own conduct, regulated accountants may also have obligations to report behaviour by colleagues that appears to breach the Code.
This should not be a cause for alarm, but it is a reason to remain alert. Comments made at work social events, activity on professional social media accounts or behaviour during business trips may all have regulatory implications. Where conduct genuinely gives rise to concern, firms will often expect it to be reported through HR or ethics channels.
The behavioural responsibilities placed on those entering the profession today are materially different from those faced by regulated accountants even a decade ago.
When to seek legal advice
If you are facing a complaint or investigation relating to professional conduct, or you are unsure how to deal with a colleague’s behaviour that may breach your regulator’s Code of Ethics, obtaining legal advice at an early stage can make a significant difference. How matters are handled initially often influences the entire course of a regulatory case.
At Kingsley Napley, we specialise in regulatory law for professional services, with particular expertise in the accountancy sector. If you would like to discuss concerns about professional conduct or behavioural misconduct, please get in touch for a confidential consultation.
About the author
Zoe is an Associate in the Regulatory team, advising regulated professionals and firms on regulatory compliance, professional ethics, internal investigations and disciplinary proceedings.
This is the first in a three-part series on professional behaviour for junior accountants.
What this series will cover
- Part 1 (this article): An introduction to the professional behaviour principle and what is expected of junior accountants.
- Part 2: Workplace scenarios involving conduct that may be perceived as bullying, harassment or discrimination, and how the regulatory framework applies.
- Part 3: Social media and off-duty conduct, exploring the grey areas around personal social media use, discriminatory posts and behaviour outside work that can still have professional consequences.
