Introducer due diligence is the process an insolvency practitioner (IP) firm runs before accepting referrals from a lead source, checking reputation, marketing conduct, data handling and ownership. Skipping it can leave the firm answering for another party's conduct. This matters because regulators and clients rarely distinguish between the introducer's behaviour and the firm's own.
A referral relationship that looks convenient at the outset can become a liability if the introducer has made misleading claims, mishandled personal data, or has beneficial owners the firm would not want associated with its brand. A short, structured check before signing an introducer agreement is far cheaper than unwinding a relationship later.
Why introducer due diligence matters: their conduct becomes your problem
When a director is referred to your firm, they experience the introducer and the IP as one journey. If the introducer overstated what your firm could deliver, or pressured a distressed director, the complaint usually lands on your desk, not theirs.
Firms are expected to be able to explain how a client reached them and to show the referral was handled appropriately. Vetting insolvency introducers before you work with them is part of demonstrating that oversight, alongside proper AML checks on referred clients once the case actually arrives.
- Scrutiny of referral routes has increased, particularly around firms marketing to companies facing an HMRC winding-up petition.
- Poor introducer conduct can trigger a complaint or reputational damage before any fee has been earned.
- Firms remain responsible for their own conduct even when a third party generated the enquiry.
Reputation and complaints history checks
Start with an honest look at how the introducer presents itself and how others describe dealing with them. Introducer background checks do not need to be exhaustive, but they should be documented.
What to look for
- Companies House filing history for the introducer's own corporate entity, including any dissolved or struck-off predecessor businesses.
- Director history — has the same person run a similarly named business before, under a different name?
- Online reviews and complaint patterns, read critically rather than taken at face value.
- Any adverse press coverage, particularly relating to distressed-company marketing.
A single negative review is rarely conclusive. A consistent pattern — pressure selling, unclear fees, or promises about stopping legal action — is an introducer red flag worth pausing on before any agreement is signed.
Reviewing their marketing and claims
An introducer's website, adverts and call scripts are the first thing a director sees, and they shape what that director expects from your firm. Review them directly rather than relying on a summary.
- Does the marketing promise outcomes — "we can stop your winding-up petition" — that only a regulated specialist could properly assess case by case?
- Does it use urgency or fear language aimed at directors who may already be under strain?
- Is it clear the introducer is not itself an insolvency practitioner or solicitor, where that is the case?
- Are referral fees or commission arrangements disclosed anywhere the director would reasonably see them?
If claims overstate what can be achieved, that gap between promise and reality becomes your firm's problem the moment the case is opened. It is worth checking marketing conduct against the terms you intend to set out in the introducer agreement, so both parties work from the same expectations.
Data protection and lead-sourcing practices
Checking lead source insolvency data handling is often the most overlooked step. An introducer who cannot explain where a director's details came from, or how consent was obtained, exposes your firm to downstream risk once that person becomes a client.
- Ask how leads are generated — search, paid advertising, affiliate networks, or purchased data lists.
- Ask what consent basis is used and whether privacy information is given to directors at the point of contact.
- Confirm how personal data is transferred to your firm securely, rather than by unencrypted email.
- Check retention practices — data should not be held longer than needed, or shared onward without basis.
Purchased or scraped data lists, and lead generation with no clear consent trail, are among the clearest red lines. If an introducer cannot answer these questions plainly, treat that as a warning sign rather than a gap to fill in later.
Financial and beneficial-ownership checks
The final layer of introducer due diligence is understanding who actually owns and controls the introducer business, and whether it is stable enough to be a sensible long-term referral partner.
- Check the People with Significant Control register at Companies House for the introducer entity.
- Cross-reference director and owner names against any prior insolvency, disqualification, or regulatory action.
- Review recent accounts for signs of financial distress in the introducer itself.
- Confirm the entity you are contracting with matches the entity actually running the marketing and taking calls.
An introducer that will not disclose its own ownership structure, or that operates through a web of similarly named entities, is difficult to hold to account if something goes wrong later.
Frequently asked questions
How often should we re-check an existing introducer?
Treat due diligence as ongoing rather than a one-off exercise. An annual review, plus a fresh look whenever the introducer changes ownership, rebrands, or shifts its marketing approach, is a reasonable minimum for most firms.
What documentation should we keep?
Keep a simple file per introducer covering the checks performed, the date, who carried them out, and any concerns raised. This evidences oversight if a regulator or client ever asks how the referral relationship was managed.
Should the checklist differ for high-volume introducers?
Yes — the more referrals an introducer sends, the more exposure your firm carries if something is wrong. High-volume relationships warrant deeper checks and more frequent review than an occasional, low-volume referrer.
What are the clearest red lines for refusing to work with an introducer?
Unclear or absent consent for data collection, marketing that promises specific legal outcomes, undisclosed beneficial ownership, and any sign of pressure tactics aimed at distressed directors are all reasonable grounds to decline the relationship.
Does due diligence replace the need for a written agreement?
No. Due diligence assesses whether to work with an introducer at all; the written agreement then sets out fees, conduct expectations and responsibilities once you proceed, including how referral fees are structured lawfully.
For reference, gov.uk sets out the wider regulatory framework insolvency practitioners work within, including guidance on money laundering regulations and firm responsibilities, the People with Significant Control requirements for checking beneficial ownership, and the Insolvency Service's role in regulating insolvency practice.
This article is general information for insolvency firms and referral partners, not legal or regulatory advice. Firms should take their own compliance or legal advice on introducer arrangements suited to their circumstances.
If your firm would like to discuss how a structured introducer relationship works in practice, start an enquiry and Harbourfirst can talk through how referrals are handled.