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 on, and many develop a practical understanding of them as they begin their careers.
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 following accounting standards. They 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 starting out in the profession today, understanding this dimension 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 just to your technical work, but 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 material changes to the professional behaviour principle. The updated 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 in complaints about poor conduct. 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 which applied when senior colleagues began their careers.
As the updated Code only came into effect in July 2025, there are as yet few regulatory decisions or tribunal cases arising from these new provisions. Regulatory proceedings take time, often years, to work through the system. The profession is therefore in a period of genuine uncertainty about how these rules will be interpreted and applied in practice. Junior accountants are navigating strengthened obligations without the benefit of an established body of case law to guide them.
Other accountancy regulators are also following suit. The 2026 ICAS Code of Ethics has also been revised to incorporate the application material developed by 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 chartered accountancy profession is therefore consistent, in that regulators are placing greater emphasis on behavioural standards, and junior accountants qualifying under either body will be subject to the same 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 should 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 broadly, and in some cases, conduct in one’s personal life can also be caught if it is serious enough to bring discredit to the profession.
Professional life vs personal life
The Code draws a distinction between “professional life” and “personal life,” though the boundary between the two is not always straightforward. Conduct will be treated as taking place in a member’s professional life if it occurs in contexts linked to their work or business practices, including:
- at social events or in private settings with colleagues or clients, even away from the office;
- situations where the member identifies themselves as an accountant or is publicly representing the profession or their employer;
- attending 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 the office and working hours. A work dinner or networking event, as well as a LinkedIn profile identifying you as an ACA student, would all be understood as part of your professional life.
Personal life, by contrast, covers conduct that is generally unrelated to a member’s professional role and obligations, such as:
- personal relationships and interactions with family and friends;
- activities during personal time with no professional context;
- social media posts where professional identity is not apparent; and
- private social events without professional connections.
However, even conduct in personal life can bring discredit to the profession if it is seriously poor and incompatible with the higher standards expected of chartered accountants. Criminal convictions, for example, may bring discredit regardless of whether they arise in a professional or personal context.
The reasonable and informed third party test
The test for assessing whether conduct crosses the line is whether a “reasonable and informed third party” would conclude that it brings discredit to the member, to ICAEW, or to the profession. This is someone who possesses the knowledge and experience to evaluate the appropriateness of conduct objectively and impartially, taking into account the relevant context.
The key principle that underpins this test is that the stronger the link between a member’s conduct and their professional role, the greater the likelihood that the behaviour 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 conduct that falls below the expected standard. More broadly, unprofessional behaviour can encompass a wide range of actions, including:
- bullying and offensive behaviour;
- physical or verbal abuse towards a colleague, client or others;
- inappropriate sexual conduct; and
- discriminatory comments or behaviour.
To illustrate the types of situations that may be of regulatory interest, ICAEW has published case studies, described as representative examples of scenarios commonly seen in conduct reports rather than actual cases. These include:
- Inappropriate social media use: An accountant making inflammatory and discriminatory comments on a public (but personal) social media account where their professional status is visible
- Rude emails to colleagues: A manager sending aggressive, critical emails to team members and, after leaving the firm, sending an email containing foul language to a former supervisor.
The ICAEW case studies 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 and later joked about the incident in front of colleagues. The Conduct Committee rejected the argument that the behaviour fell outside the scope of the Code because it took place outside office premises and working hours. Instead, it found that the business‑trip context, together with the ongoing professional relationship between the parties, 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 ICAEW severely reprimanded and fined a partner in a Big 4 firm for inappropriate conduct towards a trainee on a work ski trip. Although the event was not an official firm‑organised trip, ICAEW considered that comments made to a colleague, and in the presence of colleagues, were capable of bringing both the individual and the profession into disrepute. That connection was deemed sufficient to justify regulatory action. This demonstrates that ICAEW assesses conduct by reference to its wider professional context; it is not enough to say that behaviour falls outside the Code simply because it did not occur in the office or during working hours.
A regulated accountant’s responsibilities
All regulated accountants will know that they have to comply with their regulator’s Code of Ethics, which set out the standards the regulator expects of its members. However, societal expectations around what is appropriate or professional are constantly evolving. Conduct that might once have passed without comment can now be viewed very differently, and the line between acceptable and unacceptable behaviour is not always obvious in advance.
In addition to managing their own conduct, regulated accountants also have a duty to report behaviour which may fall foul of the various provisions within the Code.
This is not a reason for alarm, but it is a reason to be alert. Comments made at work social events, activity on professional social media accounts, or behaviour on business trips can all be relevant to professional standards. If you see conduct that genuinely concerns you, your firm will usually expect it to be reported to HR or the ethics team.
The behavioural responsibilities placed upon those entering the profession now are certainly different to those faced by regulated accountants even a decade ago.
When to seek legal advice
If you are facing a complaint or investigation related to professional conduct or are unsure of how to deal with a regulated colleague’s behaviour which may fall foul of your regulator’s Code of Ethics, early legal advice can make a significant difference to the outcome. The way in which a matter is handled in its early stages can affect the entire trajectory of a 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 any 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
This is the first in a three-part series examining the professional behaviour principle and what is required of junior accountants.
The second blog will examine workplace scenarios in detail, looking at realistic situations involving conduct that may be perceived as bullying, harassment, or discrimination, and analysing how the regulatory framework applies.
The third blog will focus on social media and off-duty conduct, exploring the grey areas around personal social media use, discriminatory posts, and conduct outside work that can still carry professional consequences.