This is the text of a letter sent to the chairman of the Institute of Chartered Accountants in England and Wales:
To: Peter Wyman, Chair, ICAEW Board, with copies to the Chairs of Audit & Risk Committees & ICAEW President
Letter of Concern: Formal Concerns Raised by Elected Employee Representatives Regarding the Collective Consultation Process
5 November 2025
Dear Mr Wyman,
We write in our capacity as Elected Employee Representatives for employees identified as being at risk, following the proposed restructuring announced on 6 October 2025.
In accordance with our responsibilities under the collective consultation framework, we consider it both appropriate and necessary to raise serious concerns with our employer when we believe there may be breaches of regulatory obligations or governance standards, or matters that could adversely affect employees, the organisation, or the wider public interest. Despite repeated efforts to engage constructively with Pamela Harding, Chief People Officer, as the designated lead for this process, we regret that our concerns have not been adequately acknowledged or addressed. As responsible employees and representatives, we cannot in good conscience disregard these issues, as doing so would compromise our integrity and, we believe, the best interests of ICAEW.
We wish to emphasise at the outset that we do not oppose the principle of organisational change, nor do we dispute the strategic direction or rationale underpinning the new ICAEW strategy and its associated pillars. We recognise the importance of transformation in ensuring ICAEW remains relevant and resilient. However, we have significant concerns regarding the way the consultation process has been conducted, the absence of transparent and meaningful information, the lack of clarity beneath the strategic rationale, and the resulting detrimental impact on employees and organisational integrity.
1. Lack of Transparency and Procedural Integrity
We are concerned that the collective consultation and related individual redundancy processes have not to date been conducted in accordance with the legal standards of transparency, procedural fairness, and meaningful engagement required under employment law and expected of a public interest body.
From our direct involvement, it is evident that material deficiencies were present before the formal commencement of consultation. These include:
· Inadequate preparatory work
· Incomplete or inconsistent data validation
· Insufficient provision of meaningful consultation with, and provision of information to,
both representatives and affected employees, particularly below the Chief Officer and Managing Director levels.
In our view, the process has not met the statutory threshold for meaningful consultation, nor does it reflect the governance standards that ICAEW is expected to uphold. The absence of procedural rigour raises concerns regarding compliance with relevant statutory duties, including those under the Trade Union and Labour Relations (Consolidation) Act 1992 and associated case law. We are also concerned that these deficiencies may undermine the business rationale for the proposed restructure, despite the significant investment ICAEW has made in the project.
2. Deficiencies in the Foundational Stages of the Restructure
The Discovery Process (Stage 1), intended to establish verified, up-to-date information on job roles and organisational structure, appears to have been substantially incomplete. In the absence of robust baseline data, subsequent assessments of redundancy risk and business need are inherently speculative and unreliable.
Similarly, the Role Selection Process (Stage 2) lacks the necessary clarity, consistency, and transparency. We have not received a sufficient explanation of the methodology, or criteria used to designate roles as “at risk.” In some cases, roles identified for redundancy appear to be replicated under different titles, while other roles not flagged as redundant have been materially altered or removed. These inconsistencies raise serious concerns about the credibility and fairness of the process and may render decisions made on this basis legally and procedurally unsound.
3. Inadequate Preparation and Governance
Given the scale and complexity of the proposed restructure, we believe that insufficient preparatory and governance measures were in place prior to launching consultation. This has given rise to operational and procedural issues, including:
• A significant data breach that identified all colleagues at risk, affecting 150+ employees and breaching their right to confidentiality in the consultation process.
• An apparent failure to ensure compliance with statutory requirements relating to the HR1 notice, resulting in its return for resubmission.
• Poor scheduling of consultation and pillar meetings, and the lack of accurate or comprehensive meeting notes being circulated.
• The repeated rejection, without adequate justification, of reasonable requests to use Teams transcription for internal and confidential record keeping purposes, including requests made on grounds of reasonable adjustment.
• Deadlines established by HR or leadership are frequently not met, with insufficient resources within the HR team and related areas frequently cited as the primary reason.
• Insufficient training and support for employee representatives, limited to a one- hour presentation by ICAEW’s legal advisers.
• The absence of clear documentation or agreed terms of reference underpinning consultation meetings.
• Avoidable stress and fatigue experienced by employee representatives due to the above factors.
• We do not believe that a full and proper equality impact assessment has been completed, which can create significant legal, reputational, and procedural risks for the organisation.
We were informed at the outset of the consultation on 6 October that the ICAEW Board had approved the restructure and the commencement of the consultation based on the proposed structure. However, on 3 November we were advised that, following the Board meeting on 30 October, nine of the new roles proposed in that structure within the Chief Information Officer pillar would no longer proceed at this stage. We were told this decision followed further Board discussions regarding the IT roadmap, which is still being developed and agreed.
This development calls into serious question why these roles were included in the original proposals if the underlying roadmap was not yet finalised, and why the proposed structure has been altered after the Board had reportedly given its approval. Such inconsistencies raise broader concerns about the transparency and governance of the process, and about whether decisions are being made on a fully informed and robust basis. They also undermine confidence among both staff and representatives that the consultation is being conducted with the necessary clarity and due diligence
We now understand, as confirmed by Pamela Harding earlier today, that this change to the CIO pillar alone may have the effect that the consultation process needs to be restarted.
4. Insufficient meaningful consultation and pre-determined outcomes
We have concerns that procedural breaches of the requirement to consult meaningfully have impeded or undermined the collective consultation and any subsequent individual consultations. For example, it appears that the required three-stage consultative process regarding ‘pooling’ has not been sufficiently met. Furthermore, during some consultation meetings and communications, comments have been made to suggest that some issues had been pre-determined, such as the structures which would not change, thereby undermining the consultative nature and purpose of the consultation process itself.
5. Insufficient Consideration of Role Interdependencies and Wider Organisational Impact
We are concerned that the restructure has not adequately considered the operational interdependencies between job roles, nor the broader organisational impact of proposed changes. A meaningful assessment of restructuring implications requires a thorough understanding of how roles interact across departments and functions.
We believe that the current approach fails to account for the potential impact of changes to “at-risk” roles on those not formally identified as such. This oversight may result in material changes to roles that are not currently flagged, which, in turn, could render them “at risk” under the principles of fair consultation and role mapping. We also believe that a broader, more inclusive consultation process is necessary to fully understand the implications of the restructure and determine whether it will achieve its stated objectives.
6. Restriction of Consultation Scope
When the need for broader workforce involvement was raised with Pamela Harding, we were advised that, for legal reasons, only employees formally identified by ICAEW as being “at risk” could be included in the consultation process. We are not persuaded that this interpretation reflects the full extent of the legal or best-practice obligations under collective consultation frameworks.
In our view, meaningful consultation, particularly in the context of a restructure of this scale, should include broader engagement with employees whose roles may be indirectly affected, or whose input could inform a more robust and inclusive process, restricting participation solely to those deemed “at risk” risks undermining the credibility and effectiveness of the consultation.
7. Misleading Information
We are concerned that, on at least two occasions, Pamela Harding seems to have misled the Representatives regarding the following:
During a collective consultation meeting, one of the Employee Representatives said that the role of a Representative in the collective consultation process appeared similar to that of a Trade Union Representative. Pamela Harding dismissed the comment as an invalid comparison, and the point was shut down as incorrect. However, on investigation, it was shown that the comparison was generally valid, leaving the Representatives feeling that they had been misled.
When the Representatives said they wanted to facilitate an informed consultation process, Pamela Harding noted that inviting certain employees at risk to attend some pillar consultation meetings was not possible, as it would constitute a breach of the procedural process. This point arose in the context that Pillar Head, David Franklin, had been allowed to have two employees who were not at risk attend a Pillar meeting because of their particular knowledge and insight, which would help ensure a productive consultation.
However, after a subsequent call with ACAS, an Employee Representative was told there was nothing in the legislation that said or implied that an employee at risk could not attend a consultation meeting of this nature if they were asked to do so by an Employee Representative (particularly when based upon a similar rationale as articulated by David Franklin, which received support from Pamela Harding). Representatives are particularly concerned by this incident, as the information they were given appears to be incorrect and undermines trust and confidence and impedes a meaningful consultation process.
These incidents raises concerns that Representatives may have been given unreliable information or misled in other respects, casting a shadow on the integrity of the consultation process more generally.
8. Detrimental Impact on Morale, Wellbeing, Trust & Confidence, and Institutional Credibility
The cumulative effect of these issues has led to a rapid and marked erosion of morale and trust among both at-risk and unaffected employees. Many staff members, at risk or not, perceive the process as predetermined, and feel excluded from a genuine dialogue regarding their futures within the organisation. The wellbeing of many staff has also been greatly impacted. The collaborative culture previously characteristic of ICAEW has been seriously adversely affected. In fact, some employees have gone so far as to describe the current culture within the organisation as increasingly toxic.
As a public interest entity, ICAEW must maintain an unimpeachable standard of fairness, transparency, and ethical governance. The manner in which this restructuring process has been managed risks undermining both internal confidence and external reputation. Recent media reports have already drawn negative attention to these matters, likely to the detriment of ICAEW’s standing.
9. Insufficient Effort to Explore Redundancy Mitigation Measures
We are further concerned that the organisation has not meaningfully explored potential mitigation measures to avoid or reduce redundancies, including:
• Voluntary redundancy schemes.
• Flexible or reduced working hours.
• Job sharing arrangements.
• Retraining or redeployment strategies.
While we understand that over 100 new roles have reportedly been introduced in the UK, many appear to be concentrated in highly specialised areas such as technology, which may not be accessible to most displaced employees. Earlier and more inclusive consideration of
mitigation options could have reduced both the scale of redundancies and their human impact.
We also note with concern that new/vacant roles have been advertised during the consultation period, despite being linked to a proposed organisational structure that has not yet been finalised or agreed. At the time of writing, the consultation remains ongoing, and the counterproposal stage has not yet concluded. In this context, the publication of new roles appears premature and risks undermining the integrity of the consultation process. It may reasonably be interpreted as indicative of a predetermined outcome, which is inconsistent with the legal requirement for genuine and meaningful consultation under the Trade Union and Labour Relations (Consolidation) Act 1992 and associated case law.
Request for Independent Review and Corrective Action
Considering the issues outlined and the potential procedural and reputational risks to ICAEW, we must express that our continued participation as employee representatives within the current consultation framework is becoming increasingly untenable.
We submit this correspondence in good faith, with the intention of safeguarding both employees' interests and the organisation's long-term integrity.
Should evidence be required to further substantiate any of the above we would be happy to provide this information.
We therefore respectfully request that the Board initiate an urgent, transparent, and independent review of the consultation process. Such oversight would help restore fairness, confidence, and trust, and ensure that the restructure is implemented in a manner consistent with ICAEW’s ethical standards and statutory obligations.
We further request that the consultation be paused pending the outcome of this independent review, and that its findings be transparently disclosed to all stakeholders.
We would appreciate a formal response to this Letter of Concern within fourteen calendar days of receipt, given the urgency of the matters raised.
We reserve all rights to amend or supplement this Letter of Concern as appropriate. We also rely on the protections afforded to us, collectively and individually, under applicable legislation, including, but not limited to, the Trade Union and Labour Relations (Consolidation) Act 1992, the Employment Rights Act 1996, and the Public Interest Disclosure Act 1998.
Yours sincerely,
Elected Employee Representatives x 14
On behalf of Affected Employees, ICAEW
Email – icaewemployeerepresentatives@gmail.com
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