Farepak auditors Ernst & Young and one of its former partners are facing disciplinary action from the Financial Reporting Council (FRC).
The FRC accused ICAEW members, EY and auditor Alan Flitcroft of misconduct and failing to meet expected auditing standards when auditing failed Christmas savings firm Farepak.
The company, which people made regular payments to in order to save up for Christmas gifts and hampers, entered administration in 2006 leaving no money available to creditors.
Around 120,000 savers were left with losses of £37m, which minister for consumer affairs in 2006 Ian McCartney called a "national emergency".
Following this, nine Farepak directors, including their finance director, faced disqualification but the High Court case collapsed.
The FRC made a disciplinary former complaint into EY and Flitcroft's conduct when auditing accounts ending 28 April 2005.