Code of Ethics: Are non-compliance provisions working?

Author: ICAEW Insights

Apr 23, 2026

The accountancy profession is invited to share its practical experience of Non-Compliance with Laws and Regulations (NOCLAR) and using the restructured Code of Ethics.

Key takeaways

• It’s been almost seven years since IESBA updated the Code of Ethics to include NOCLAR.

• It is reviewing the implementation of these changes to ensure they are meeting intended aims.

• Members are invited to take part in the review process.

• Feedback on the restructured Code of Ethics and NOCLAR can be provided via two surveys with deadlines on 3 July and 30 July respectively.

In July 2017, the International Ethics Standards Board for Accountants (IESBA) introduced new provisions into the Code of Ethics. These were intended to guide professional accountants on how to respond in the public interest, to actual or suspected Non-Compliance with Laws and Regulations (NOCLAR) committed by a client, employer or others working for or under their direction.

Two years later, in 2019, IESBA restructured the entire Code of Ethics. The intention was to distinguish clearly between mandatory requirements and application material, and strengthen emphasis on the fundamental principles of ethics and independence in the Code. The aim was to make the Code easier to adopt and apply, and to maintain and increase trust in the accountancy profession.

IESBA is now undertaking a post-implementation review of the NOCLAR provisions, and of the restructured Code of Ethics itself. The review’s aim isto assess whether they are achieving their intended objectives by identifying benefits and implementation challenges. It will then inform any actions the IESBA may need to take in response.

Members of the profession are invited to share their practical experience of the NOCLAR provisions and using the Code. Views will be obtained initially via two surveys issued by IESBA.

The surveys are open to individual professional accountants as well as firms, those charged with governance, investors, and other users of financial and nonfinancial information.

The surveys seek information about applying the NOCLAR framework, identifying what works well and where challenges remain, and whether the restructuring of the Code in 2018 has improved the clarity and usability of the Code.

Following analysis of feedback to the surveys, the IESBA Board will consider whether any further action (including the development of standards or non-authoritative material) is required.

David Gomez, ICAEW’s Senior Adviser, Ethics, said: “ICAEW’s Code of Ethics is based on the IESBA Code. We encourage members to share their views on the useability of the Code with IESBA, including the distinction between mandatory requirements and application material, and whether the language used in the Code is clear, readable and understandable.”

Peter van Veen, ICAEW’s Director of Governance and Ethics, said: “The Code of Ethics sets out specific requirements that a professional accountant must follow if they encounter potential NOCLAR situations. It is vitally important that feedback on how these provisions are working in actual practice is shared with IESBA.”

[ICAEW Insights]