Tracing Directors as the Insolvency Service Expands Its Enforcement Remit

Tracing Directors as the Insolvency Service Expands Its Enforcement Remit

On 4 August 2026 the Insolvency Service published its Annual Plan for 2026 to 2027, and the direction of travel is clear. The agency intends to investigate more company directors, secure more disqualifications, and take a harder line on those who reoffend. For creditors and the solicitors who act for them, that shift makes tracing directors a practical priority, because public enforcement protects the wider market rather than returning money to any single creditor.

What did the Insolvency Service announce on 4 August 2026?

The plan is organised around three purposes: maximising returns to creditors, tackling financial wrongdoing, and supporting those in financial distress. Under the wrongdoing heading the agency has set several commitments for the year. It will transfer the casework and staff of the National Investigation Service, which examined COVID-19 financial support fraud, so it can investigate a wider range of cases. It will use new funding to set up a dedicated taskforce to identify and disqualify directors who repeatedly exploit the insolvency system, a pattern it names as abusive phoenixism. It will develop plans to modernise the civil enforcement regime following its earlier consultation, and will publish the government response to that consultation during the year. It also intends to maximise recoveries under the Proceeds of Crime Act. The agency employs around 2,000 people across 11 regional centres, including examiners, investigators and legal professionals.

Why does tougher enforcement increase the need for tracing directors?

Disqualification and criminal sanctions protect the public, but they do not pay a creditor. A creditor still has to bring or enforce its own civil claim, and that begins with knowing where a director lives and which companies they now sit behind. Repeat directors are, by design, difficult to pin down. They dissolve one company and surface behind another, sometimes using variant spellings of a name, an accommodation address, or a relative as an intermediate contact. Registered office details go stale quickly once a company stops trading. Tracing directors, and confirming a current residential address, is the step that makes a statutory demand, a claim form or a committal application capable of valid service.

 

How does tracing directors work when a phoenix company is involved?

A phoenix pattern leaves a trail across public and proprietary records. A people tracing exercise cross-references appointment histories, previous and current addresses, electoral information and connected individuals to build a verified picture. The object is not merely a name but a confirmed address that is good for service, together with a map of the successor companies through which value may have passed. Carried out lawfully, under a recognised data protection basis, this work lets a solicitor act before people and records scatter further. Our guide to how tracing agents find people sets out the sources involved and their limits.

What should a creditor’s solicitor do next?

The plan sets milestones for the year, including onboarding the transferred investigators, triaging their casework, forming the abusive phoenixism taskforce, and publishing the government response to the civil enforcement consultation. Solicitors acting on recovery need not wait for that programme to mature. Where a company has failed and a director has moved on, tracing directors early preserves the option of prompt service and enforcement, and it often shapes whether a claim is worth pursuing at all. The reforms outlined in August 2026 point to a busier enforcement landscape, and the creditors best placed to benefit are those who already know who they are chasing and where to find them.

If you need to locate a director or confirm an address that is good for service, fill in the form below to speak to the Tremark team about people tracing.

Frequently Asked Questions

Is tracing directors lawful under data protection rules?

Yes, where there is a recognised lawful basis, such as the legitimate interests of a creditor pursuing a genuine claim, and where the investigator follows an approved code of conduct.

How long does it take to locate a company director?

A straightforward address confirmation can take a few days. Building a full picture of connected companies and individuals takes longer and depends on the records available.

Can you trace a director who has moved abroad?

Often yes, although the sources and timescales differ, and any subsequent service on that person abroad then follows its own procedural rules.