The revisions to the 2025 ICAEW Code around the role and mindset of professional accountants strengthen the relationship between compliance with the Code and the fundamental principles. It emphasises the obligation of professional accountants to act in the public interest, and to comply with both the spirit as well as the letter of the Code. 

Compliance with the requirements of the Code does not always mean that a professional accountant will have met his or her responsibility to act in the public interest. The revised code now recognises that there may be unusual or exceptional circumstances in which compliance may lead to a disproportionate outcome. 

In such circumstances, advice should be sought from a professional or regulatory body. However, it is required in all cases that professional accountants should behave in a manner that is consistent with the profession’s responsibility to act in the public interest. 

In this update to the Code, the definitions to the fundamental principles of Objectivity and Professional Behaviour have also been enhanced. Significantly, this update introduces the concept of “having an inquiring mind”. This concept is intended to capture the thinking that is required for professional accountants to apply the conceptual framework as they carry out their professional activities. 

Gareth Brett, ICAEW’s Interim Director of Trust and Ethics, explains: “While ‘having an inquiring mind’ might sound similar to ‘professional scepticism’, they are actually distinct concepts: an inquiring mind is a broader requirement that applies to all professional activities and involves being open to questioning and critically evaluating information encountered; professional scepticism is a specific mindset required when performing audits, reviews, and other assurance engagements.”

New sections also express the concepts of an inquiring mind and professional judgement as separate concepts under R120.5. 

The definition of the fundamental principle of integrity has been strengthened. Professional accountants are now required to have “the strength of character” to act appropriately in difficult situations. 

This means standing one’s ground when confronted by dilemmas and difficult situations, or challenging others (as and when circumstances warrant), in a manner appropriate to the circumstances. David Gomez, ICAEW’s Senior Lead, Ethics, notes that these provisions reflect the vital importance of speaking up within the profession, and the role of professional accountants in combatting economic crime.

Revised sections reflect the impact of technology on the profession, such as the risks of technology impairing a professional accountant’s objectivity (R112.1). They expand the fundamental principle of professional competence to include a requirement to maintain a continuing awareness and understanding of relevant technology-related developments (113.A2). In a separate article, we will explore further detailed guidance on technology issued by IESBA and which will be incorporated into ICAEW’s 2025 Code of Ethics.

New sections in this update emphasise the importance of professional accountants’ awareness of bias. The revised Code now lists further examples of potential bias that professional accountants should be aware of when exercising their professional judgement; and the mitigations that they can put in place to offset the risk of bias (120.12 ). 

Also included in this update are revisions which stress the responsibility of professional accountants to promote an ethics-based culture within their organisations and to “exhibit ethical behaviour” when dealing with others as part of a professional or business relationship (120.13). 

The revised Code points out that organisational culture is most effective when demonstrated by leaders acting ethically, both internally and when dealing with third parties. David Gomez explains that these new revisions apply to all professional accountants: “Everyone has a role to play in contributing to an ethics-based culture within their organisations.” 

Further detail on the new revisions in the 2025 ICAEW Code of Ethics can be found here.