In recent years there have been a number of instances in which regulators have taken action against large and high profile accountancy firms over cheating in examinations and assessments.

Most recently, the Dutch arms of Deloitte, PwC and EY were fined $8.5m by the US regulator, the Public Company Accounting Oversight Board (PCAOB), for widespread cheating carried out in internal training and ethics assessments for auditors and accountants.

The integrity of the examination and assessment process is essential to ensuring confidence in the profession and the UK accountancy regulators have sought to take steps to combat academic misconduct. 

For example, in 2024, the Financial Reporting Council (FRC) required the Big Four audit firms to disclose the measures put in place to prevent examination cheating facilitated by Generative AI (GenAI).

It is, perhaps, against this backdrop that there has been an increase in the number of complaints of academic misconduct being reported to the UK’s accountancy regulators and a rise in the number of cases being considered by disciplinary tribunals.

The types of conduct being complained about are many and varied, and include use of unauthorised materials in an exam, use of GenAI during remote exams, use of colleagues’ work in the preparation of ‘coursework’, and the sharing and use of peers’ work and model answers.

More specifically, an ICAEW provisional member I acted for relatively recently obtained his colleagues’ answers about their experience and competency, and relied on these rather than his own when completing his Level 7 Project Report.  

This was identified by software used by his employer to carry out plagiarism checks, he was dismissed and referred to his regulator and faced disciplinary proceedings resulting in a severe reprimand, financial penalty and costs.

In another matter I acted in, an Association of Taxation Technicians (ATT) student member was alleged to have used GenAI during a remote open book exam. The use of the GenAI was identified by the monitoring software used to detect such activity and a referral was made to the Tax Disciplinary Board (TDB) for disciplinary investigation. 

In fact, owing to an ambiguity in the ATT’s rules relating to the accepted use of GenAI and the specific circumstances of this case, the disciplinary proceedings were ultimately dropped. 

However, there have been a number of similar cases before the TDB where use of GenAI contrary to the ATT’s Examination Regulations has been established and the students have been removed from the register.

Better detection

It is apparent from the cases coming through the system that employers, examination boards and regulators now have systems in place to detect cheating.  These range from manual identification of obvious similarities by the person marking a piece of work, to the use of sophisticated software which identifies whether the work submitted has been plagiarised, and real time monitoring of remotely conducted examinations.  

Therefore, there is a real risk that any attempt to cheat, either in an examination or in coursework, stands a strong chance of being detected. The consequences if detected can be severe and, in some circumstances, career ending. These range from being marked with a zero by the examination board, being investigated and dismissed by an employer and/or facing disciplinary investigation by their regulator.  

If allegations are proved at a disciplinary hearing, although it is not always the case, there is a real risk of being removed from the register. Even if the outcome is a lesser sanction, there will generally be an order to pay costs and a disciplinary record, which is published by the regulator and is likely to be disclosable to future employers.  

Studying for an accountancy or tax qualification is intellectually demanding, requires dedication and a real time commitment. To some it will be tempting to seek to circumvent the system to save time or to derive a competitive advantage. To others, they may fall into a trap of not understanding the rules and inadvertently using material which is not allowed.  

It is important for any student or candidate subject to assessment to make sure that they understand the examination and ethics rules with which they must comply, and perhaps, most importantly, the fundamental principles of integrity and professional behaviour.  

There is also clear guidance from the regulators as to what is and is not permitted, for example, the section on student conduct and behaviour on the ICAEW website.

For those that do find themselves in hot water professional advice at an early stage is essential in order to mitigate any adverse consequences.

For accountancy firms with employees and trainees who are being assessed, any firm, whether large or small, is expected to implement policies and procedures to identify cheating in both formal and informal assessments.  

What is required will be different from firm to firm and but generally, at the very least, ought to include clear guidance on the acceptable, if any, use of Gen AI and the work of others, training, and a robust and fair process of investigation when suspected cheating is identified. It must also not be forgotten that where concerns are identified there is a duty to report the individual to the relevant regulator.

About the author

Matthew Corrie, barrister at 5 St Andrew’s Hill Chambers

Read more articles about Exam cheating here