An evidential standard for the transmission of a distressed business file to a licensed insolvency practitioner. Six gates, four verdicts, one dated artefact per file.
First issued 15 November 2025, following engagement with the Financial Conduct Authority and the Solicitors Regulation Authority on their structured terms through which the compliance parameters behind it were established. This edition, BPCS / 2026.01.
Position
What is actually being relied upon
When a director first brings a company to a practitioner, what arrives is usually a conversation, a set of filed accounts up to twenty one months old, and whatever the director says on the day.
No artefactNone of it is a per file record. Nothing is dated to the moment the director declared their position, and nothing records who authorised the handover or whether that person held office.
Late by constructionThe register is the only independent source in that picture. Accounts are filed months after the period they describe. A judgment follows proceedings. A petition follows the matured debt.
What this fixesWhat the business was, who said so, what they declared about their own position, and when, at the point of transmission, in a form the receiving firm can validate rather than take on trust.
The measure
Six gates per file
Each gate tests against a source record. Where an artefact never existed, the standard reports its absence rather than manufacturing it. Attestation is not an artefact.
Gate 01 Determines
Entity
The subject is resolved to a registered entity, with company number, live status and registered office matched to the register as at the issue date. Trading name alone does not resolve an entity.
Fails onno number resolved, a number that does not correspond to the business described, or a status the register does not support.
Gate 02 Determines
Authority
The person completing the passport is evidenced as a director or an authorised officer of that entity at the date of completion. Evidenced, not asserted.
Fails ona completer who cannot be tied to the appointed officers, a resigned officer, or an intermediary completing on the business's behalf without a recorded authority.
Gate 03 Determines
Instruction
The client directed the transmission to the named firm, on a dated record, with the contact permission and the introduction permission captured as two separate acts rather than one combined consent.
Fails ona single bundled permission, an introduction made without the second act, or a transmission for which no client instruction exists.
Gate 04
Declaration integrity
The declared position as at the completion date, unaltered since issue, with every field carrying its evidence class on the face of the record. What the director stated is marked as stated.
Fails onalteration after issue, a field whose evidence class cannot be established, or a declaration reconstructed after the fact.
Gate 05
Claim provenance
Where the file carries a claim as an estate asset, the claim traces to an evidenced origination on the same test the Claim Passport Certificate Standard applies on the consumer side. A quantum without a provenance is a number, not an asset.
Fails onan origination that cannot be evidenced, a chain broken by an originator that has since gone, or a value asserted without a basis.
Gate 06
Duplication
The claim is tested against multi point accrual to establish whether it has already been advanced elsewhere, regardless of who advanced it, who originated it or which entity holds it now. The outcome is reported with a confidence position and the supporting evidence attached.
Fails ona live advance elsewhere, or a conflict the record cannot resolve.
Gate 01 of 06
Three gates determine the file
Gates 01, 02 and 03 fix the outcome regardless of anything else the file holds. A passport that cannot establish the entity, the authority of the person declaring, or the client's own instruction to transmit is uncertifiable, whatever its score on the remaining three.
That is deliberate. Those three are the questions an office holder is answerable for, and no volume of supporting detail substitutes for them.
Outcome
Four verdicts
Certified
All six gates satisfied. The artefact issues with the full evidence class map and a validation reference.
Qualified
The three determining gates are satisfied and one or more of gates 04 to 06 carries a stated exception. The exception travels with the artefact and is named, not summarised away.
Unevidenced
The position could not be established because the record does not exist, rather than because it is adverse. Absence is reported as absence.
Failed
A determining gate is not satisfied. The file does not certify and no artefact issues.
The artefact
One certificate per file
Each certified or qualified passport produces a single artefact carrying:
Standard reference and editionIssue dateCertificate referenceVerdictGate by gate positionEvidence class of every fieldAny exceptionValidation route to the register
The register is centralHeld centrally and never distributed. A receiving firm validates a reference against it, which is what allows a file to be relied upon by a party who was not present when it was completed.
What it does not doIt expresses no view on whether the business is solvent or insolvent and indicates no procedure or course of action. It certifies the record. The determination belongs to the licensed practitioner.
Evidence
Every field carries its class
A certificate that blurs what was checked against what was said is worth less than no certificate at all, because it invites reliance it cannot carry. Each field is marked.
Register matchedChecked against an official register on the issue date, with the source and the date recorded.
Platform verifiedEstablished from records held on the platform, independent of the declaration itself.
StatedDeclared by the completer. Recorded as their statement, dated, and never presented as verified.
AbsentSought and not found. Reported as absent rather than inferred or filled.
Every position recorded in a certificate is classified as VERIFIED, REPORTED or WOLF ASSESSMENT, and the classification travels with the artefact.
Application
Date of knowledge
A dated declaration by a director of their own arrears, demands and called guarantees is evidence of what that director knew, and when.
That question sits at the centre of antecedent transaction work and of any argument about the point at which a director should have concluded there was no reasonable prospect of avoiding an insolvent outcome. It is ordinarily reconstructed afterwards, from correspondence, bank records and recollection, at considerable cost and with a contested result.
A certified passport fixes it contemporaneously, in the director's own hand, before an appointment exists and before anyone has an interest in the answer. No product built on filed data can produce it, because filed data records the company, not the director's own account of what they knew on a given day.
Held as a flag, not a verdict. Whether a claim carried on the file vests in the estate, and whether the office holder can pursue it, is a legal question. The standard records the asset and its provenance. It does not determine vesting.
Portfolio
What a receiving firm sees across a book
Certified percentage as at a date, with the failure pattern by gate.
Gate failure rate by intake route, so a route producing weak files is visible rather than averaged away.
Aggregate estate asset value carried across passports received, with the provenance position on each.
Cure cost where a file is remediable, and the point at which it is not.
Cohort dating across declarations, which on this side of the standard means the distribution of declared knowledge across a book of directors.
Context
Where the certified file comes from
The standard is applied to passports arising from two distinct layers, and the distinction matters to anyone relying on the artefact.
The declared layer. A business holding a passport account raises its own hand, completes the structured request, selects a firm and transmits. The declaration is the client's act throughout. No record is released by any other route.
The modelled layer. Separately, a probability model scores distress across the whole UK business population by area, sector and size, from public data. It identifies where distress sits. It names nobody, and it forms no part of any certificate.
The two are held apart by design. A modelled score is never written into a certified field, and a certified declaration is never presented as a modelled output. Where the layers are read together, the reading is an assessment and is labelled as one.
01 Issued at sourceCertification is applied at the point the passport is completed and transmitted, while every record it tests is still reachable.
02 Sample firstWhere an existing book is brought to the standard, a defined sample establishes the certified percentage and the failure pattern before any full run is commissioned.
03 Full runApplied at book scale, producing file level verdicts, the cohort position and the exception register.
04 Re testCurrency decays. A declaration is true as at its date and no longer, so the certified percentage is reported as at a date rather than in general.
Certification is held independently of the case management layer. Where the party that originated the volume also supplies the system holding the origination records, the record and its author trace back to one party, and no audit within that arrangement is independent of it.
Distinction
What this is not
Not an attestationEvery gate tests against a source record. A firm's own confirmation that a thing is so is not an artefact.
Not a keystroke auditAn audit trail records what a handler typed. It cannot reach an event that happened before the file was opened.
Not a compliance sign offA sign off approves material at a point in time. Certification is scored, dated, reproducible and issued per file.
Not a credit or distress scoreThose describe a company from the outside. This records what the business is and what its director declared, from the inside, on a date.
Not adviceThe standard expresses no view on solvency, on procedure or on any course of action.
The time limit nobody prices
Provenance and authority evidence sit with the entity and its officers. Where a company is wound up, struck off or dissolved, and its officers disperse, the record of who held office and what they declared goes with it. Certification carried out while the entity is live is recoverable. The same exercise attempted afterwards is not, at any price.
Regulatory context
Who regulates the practitioner receiving the file
An insolvency practitioner in the United Kingdom is authorised and regulated by one of three recognised professional bodies, each recognised for the purposes of section 391 of the Insolvency Act 1986.
ICAEWICASInsolvency Practitioners Association
The Insolvency Service is the oversight regulator. The Secretary of State holds a set of oversight sanctions over the recognised bodies, introduced into the Insolvency Act 1986 by the Small Business, Enterprise and Employment Act 2015, and the bodies account to the Insolvency Service for how they supervise their own members. The Association of Chartered Certified Accountants ceased to be a recognised professional body with effect from 1 March 2021 and no longer licenses practitioners.
What the standard is written against
The certificate imposes no obligation on the practitioner and creates no regulatory status. It is built so that a file arriving under it supports obligations the office holder already carries.
Insolvency Act 1986 and the rulesThe determining gates on entity and authority address the two questions an office holder must be able to answer about who instructed the work and in respect of what.
Statements of Insolvency PracticeIssued through the Joint Insolvency Committee and applied by each recognised body. The evidence class map and the exception register are built to be producible on a monitoring visit rather than assembled for one.
Insolvency Code of EthicsGate 03 records the client's own instruction and the two separate permissions, which is the record that evidences how the introduction arose.
Connected party disclosureWhere a file carries a connected party position, it is recorded and dated at the point of declaration rather than reconstructed after an appointment.
Redress claims as estate assetsThe three recognised bodies have issued joint interim guidance for office holders on motor finance redress claims, in place while the challenges to the Financial Conduct Authority scheme continue. Gate 05 exists so that any claim carried on a file arrives with its provenance attached rather than as an asserted value.