Andrew Dix lost his licence. The estate still has no answer.

On 20 October 2026 the Insolvency Service published the outcome against Andrew Dix, an insolvency practitioner from Essex. An ICAEW tribunal found, by his admission, that on 29 June 2023 he transferred £27,000 from an insolvency estate account for a purpose other than the liquidation.

What this means if you are a director: the person who takes control of your company’s money can be found unfit and still leave creditors without a public account of where that money went. The notice that landed this week does not name the liquidation, the recipient, the purpose, whether the £27,000 came back, or any final loss to the estate. It does not record a criminal conviction or a compensation order. If you are sitting with a letter tonight, that gap is the point. The official account protects the public by withdrawing an authorisation. It does not tell the people whose money was moved what they got back.

The tribunal found Dix had breached Statement of Insolvency Practice 11, which sets the rules for the proper purpose and security of estate money, and the professional behaviour principle in the Insolvency Code of Ethics. It took account of a previous regulatory and disciplinary record which, it said, showed a pattern of disregarding obligations. It was not satisfied he was fit to practise. On 17 November 2025 it ordered his insolvency licence withdrawn and ordered him to pay £7,938.50 in ICAEW tribunal costs. He appealed the sanction and the costs. On 13 May 2026, after he confirmed he no longer sought to challenge the order, the appeal committee dismissed the appeal by consent and upheld it. Appeal costs of £9,474.25 took the total to £17,412.75. Withdrawal took effect on 13 July 2026. The Insolvency Service does not say those costs have been paid.

Read that figure for what it is. It is tribunal and appeal costs awarded to ICAEW. It is not a fine. It is not repayment to the estate. Licence withdrawal removes Dix’s ICAEW authorisation to take statutory insolvency appointments. It is not, by itself, a director disqualification under the Company Directors Disqualification Act 1986, and it is not a general ban on every kind of business. The published notice does not say he continued to practise, obtained another authorisation, or was separately barred from acting as a director. It does not say why he stopped challenging the order. Scotland and Northern Ireland have their own insolvency rules; this notice concerns an ICAEW licence.

The dates are public and still incomplete. The transfer was on 29 June 2023. The tribunal order came on 17 November 2025, nearly two years and five months later. Withdrawal took effect on 13 July 2026, almost eight months after the order. The notice does not say when the conduct was reported or when the investigation began. Those dates do not prove the system was slow. They also do not prove it was prompt. What they prove is a long public silence, then a short notice that leaves the money unexplained.

Put that beside what a director under the cosh is told, in public, about a smaller sum. On 18 April 2023 the Insolvency Service said Craig McCourt, sole director of an electrical installation company in Ross-shire, had been disqualified for 11 years. The company had stopped trading in September 2019, so it was not eligible for Bounce Back Loan funding. Investigators said he transferred an initial £15,000 loan to another account and applied for a £5,000 top-up in November 2020, after the company had been dissolved. The ban stops him being involved in forming or managing a company without the court’s permission. The findings are not the same as Dix’s. McCourt’s case was about ineligible applications as well as transfers. Dix admitted a transfer of estate money and had a previous disciplinary pattern the tribunal did not spell out. Amounts alone do not prove one case was treated more softly. The comparison that does stand is about what the public is allowed to know, and about what each sanction actually does.

McCourt’s ban has a stated term and bites on company management. Dix lost a professional authorisation. The published notice gives that withdrawal no fixed term. McCourt’s statement names the company context, the sums and the ineligibility. Dix’s notice does not name the estate. A director who moves company money the wrong way is named, timed and restricted in a way a neighbour can understand. A practitioner who admits moving £27,000 of estate money for a purpose outside the liquidation loses a licence, is ordered to pay costs to his regulator, and the creditors of that estate are not told, in the notice that is supposed to account for it, whether their money came back.

Directors are also ordered to pay the money back. In a separate case the Insolvency Service published on 1 July 2025, building contractor Tahir Haq was said to have overstated company turnover to obtain a £50,000 Bounce Back Loan when the company was entitled to just over £3,000. The High Court banned him as a director for 11 years and ordered repayment of the money obtained above entitlement, with interest and costs. That is a recovery order on top of disqualification. It is not a bill of the regulator’s hearing costs. The Insolvency Service’s 2025 review of practitioner regulation says that, in Bounce Back Loan cases where an insolvency practitioner was in office, it disqualified 688 directors for an average of nine years, and obtained 50 compensation orders and 70 compensation undertakings with a combined value of £4.3 million. Those figures are for that group of loan cases. They are not a picture of every distressed director. They do show the enforcement route the Service uses when it decides a director took loan money he should not have had: a public ban, and in many of those cases an order or undertaking aimed at the money.

The Service says practitioner regulation is there to protect the public and to promote fair, consistent outcomes. Recognised professional bodies authorise practitioners. The Service oversees the regime. ICAEW sat in judgment on Dix, found him unfit, withdrew the licence and was awarded £17,412.75 in costs. Dix pays with his authorisation and with that costs order, if it is collected. The unidentified estate and its creditors carried the exposure. The notice does not establish that they have been paid. That is the double standard a director should see clearly, without pretending the cases are the same offence. When the state comes for a director over Bounce Back Loan money, the published account often names the company, the sum, the ban and, in cases such as Haq’s, the repayment. When a practitioner admits moving estate money, the published account names the admission, the licence and the regulator’s costs, and stops. Who decided: an ICAEW tribunal, then an appeal committee dismissing by consent. Who benefits from the order as published: ICAEW, in costs, and the public, in the removal of an authorisation the tribunal said should not continue. Who pays, on the face of the notice: Dix. Who is not shown to have been paid: the estate.

None of this means formal insolvency is always wrong. A creditors’ voluntary liquidation (CVL) or a company voluntary arrangement (CVA) can be the right choice. It is a choice. The first person who tells you it is the only choice is often the person who will be paid to run it. Personal guarantees, an overdrawn director’s loan account and disqualification risk are survivable if you deal with them before someone else chooses the procedure. HMRC is a creditor with a timetable, including time to pay, not a force that can be ignored and not an enemy that can be outwitted by silence. Wrongful trading is continuing to trade when you knew, or ought to have known, there was no reasonable prospect of avoiding insolvent liquidation, without taking every step to minimise loss to creditors. A winding-up petition is a court process with dates. A bounce back loan that was taken when the company was not eligible is a separate personal risk, as McCourt and Haq show.

If a letter about disqualification arrives, government guidance says the Insolvency Service should set out the alleged unfit conduct, that it intends to start proceedings, and how you can respond. You can defend in court or offer a voluntary disqualification undertaking. The guidance says to consider legal advice. Company insolvency does not by itself make you liable for every company debt. Personal liability arises in particular cases: a personal guarantee you signed, an overdrawn director’s loan account, wrongful trading, misfeasance, or a compensation order. If your worry is the practitioner, not a disqualification letter, the Service says you use the practitioner’s own complaints process first, then the IP Complaints Gateway, with evidence. The gateway looks at disciplinary conduct. It cannot itself award compensation or change a decision in the insolvency. For money, the routes it points to are legal advice and, where it fits, a court application.

The Dix notice is the official account. Tested against what a creditor would need, it leaves out the only facts that would show whether the sanction served the people whose money was moved. That omission is not a small drafting point. It is the difference between a regulator closing a file and an estate being put back.

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