An overview of the key revisions to the 2025 edition of ICAEW's Code of Ethics which are intended to promote the role and mindset expected of all professional accountants.
Supporting the Code
This document is no substitute for reading the revised ICAEW Code of Ethics in full. It is your professional responsibility to familiarise yourself thoroughly with the Code when it is published in March 2025.
The key revisions in the 2025 edition of the ICAEW Code of Ethics relating to the role and mindset expected of accountants include:
- New sections highlighting the wide-ranging role of the accountancy profession in society and the relationship between compliance with the Code, and the responsibility of a professional accountant to act in the public interest (section 100.2-100.4; R106- R107; 110; R115.1(b)).
- Revised sections which enhance the definition of the Fundamental Principles of Objectivity and Professional Behaviour (sections 110.A1; R112.1).
- A revised section which strengthens the Fundamental Principle of Integrity by requiring professional accountants to have the “strength of character” and the determination to act appropriately in difficult situations (section 111).
- Revised sections that reflect the impact of technology (sections R112.1; 113.A2).
- A new section requiring all professional accountants to have an inquiring mind when applying the Conceptual Framework (section 120.5).
- New sections highlighting the importance of being aware of bias and emphasising the responsibility of all professional accountants to encourage and promote an ethics based culture within their organisations (section 120.12 and 120.13).
Acting in the public interest
Section 100 includes new subsections which emphasise that compliance with the Fundamental Principles and application of the Conceptual Framework lie at the heart of compliance with the Code and play an important role in enabling professional accountants to meet their responsibility to act in the public interest (see sections 100.2-100.4).
A new section (Section 100.6 A2) emphasises that compliance with the Code includes “giving appropriate regard to the aim and intent of the specific requirements”. The intent of this change is to emphasise that professional accountants need to comply not only with the letter of the Code, but also with its spirit.
New Section 100.6.A3 acknowledges that there may be unusual or exceptional circumstances in which a professional accountant considers that complying with the Code might not be in the public interest or might lead to a disproportionate outcome. In such circumstances, the professional accountant is encouraged to consult with his or her professional or regulatory body.
Revised section 110.A1(e) and R115.1(b) now emphasise that professional accountants should behave in a manner that is consistent with the profession’s responsibility to act in the public interest. This revision was intended to reinforce the relationship between compliance with the Fundamental Principles and a professional accountant’s responsibility to act in the public interest.
Strength of character to act appropriately
Section 111.1 A1 has been revised to require professional accountants to have “the strength of character to act appropriately, even when facing pressure to do otherwise or when doing so might create potential adverse personal or organisational consequences.”
Revised section 111.1 A2 defines “acting appropriately” as:
- (a) Standing one’s ground when confronted by dilemmas and difficult situations; or
- (b) Challenging others as and when circumstances warrant, in a manner appropriate to the circumstances.
Having an inquiring mind
New sections establish 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.
The new sections express the concepts of an inquiring mind and professional judgement as separate concepts under R120.5.
The revised section 120.5 A1 clarifies that “having an inquiring mind” is a prerequisite for obtaining an understanding of the known facts and circumstances which are required for the application of the Conceptual Framework.
There are two elements of “having an inquiring mind” which are set out in the revised section 120.5 A1 (a) and (b). These are: considering the source, relevance and sufficiency of information obtained, as well as being open and alert to a need for further investigation or other action which may be necessary in the light of any new information that comes to the attention of the professional accountant, or where circumstances may have changed.
A new section, 120.5 A3, states that, in addition to having an inquiring mind (which is required for all professional activities), professional accountants undertaking engagements to which auditing, review and other assurance standards apply, are also required to “exercise professional scepticism”- which includes a critical assessment of evidence.
Bias and organisational culture
New sections 120.12 A1- 120.12 A3 introduce bias as an important element to be considered when applying the Conceptual Framework. The purpose of this revision is to highlight the importance of being aware of potential bias in the effective exercise of professional judgment and application of the Conceptual Framework. These sections list examples of potential bias that professional accountants should be aware of when exercising professional judgement, and actions that might mitigate the effect of bias.
New sections 120.13 A1-120.13 A3 highlight the importance that a positive internal organisational culture has on the effective application of the Conceptual Framework.
These new sections emphasise that such a culture is most effective when demonstrated by the organisations and their leaders acting ethically, both internally and when dealing with third parties.
New section 120.13A2 clarifies that leaders and those in managerial roles have a role in promoting the importance of the ethical values of the organisation. New section 120.13 A3 reminds individual professional accountants of their role in promoting ethical behaviour and culture in their organisation, taking into account their position and seniority.
The impact of technology
The following revisions reflect the impact of technology on the role and mindset required of professional accountants.
Section R112.1 has been amended so that the definition of the fundamental principle of “Objectivity” now highlights the risks of technology impairing a professional accountant’s objectivity.
New section 120.12 A2 includes “automation bias” in the list of examples of bias to be aware of in the exercise of professional judgment.
Revised section 113.1 A3 highlights the importance of professional accountants maintaining an awareness and understanding of technology related developments when complying with the Fundamental Principle of “Professional Competence and Due Care”.
The principle of objectivity
The description of the Fundamental Principle of “Objectivity’ has been revised, to incorporate reference to a wider range of factors which might potentially impair a professional accountants objectivity. Section R112.1 now provides that Objectivity “requires an accountant to exercise professional or business judgement without being compromised by:
- a) bias;
- b) conflict of interest; or
- c) undue influence of, or undue reliance on, individuals, organisations, technology or other factors.
Why has ICAEW revised the Code of Ethics?
ICAEW’s 2025 Code of Ethics is based on the Code of Ethics for Professional Accountants of the International Ethics Standards Board for Accountants (IESBA) published by the International Federation of Accountants (IFAC) in 2024 and is used with permission of IFAC.
As a member of IFAC, ICAEW is required to incorporate revisions to its Code of Ethics which have been introduced by IESBA.