Financial Reporting Council updates disclosure guidance amid regulatory reforms

Paul Jenkins
Paul Jenkins
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The Financial Reporting Council (FRC) has released an updated version of its guidance to help companies fulfill their disclosure obligations in strategic reports. The revisions aim to assist reporting teams in making disclosures that match the size, complexity, and circumstances of each entity. The changes incorporate recent legislative updates, including the UK Corporate Governance Code 2024 and new requirements for directors’ report disclosures. The FRC also revised its ‘Principles of Communication’ and improved the structure and usability of its guidance.

In addition to the main guidance, the FRC published updated Scoping Tables. These are intended to help entities comply with Companies Act 2006 disclosure requirements related to strategic reports, directors’ reports, and energy and carbon reporting, particularly reflecting payment practices reporting within directors’ reports.

Recent government regulations have brought certain provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) into force. Notably, section 49 removes private companies’ option to keep information about their members on the central register at Companies House; all companies must now maintain their own registers. Transitional provisions apply for those previously using the central register.

Companies House announced that identity verification for individuals filing documents will be postponed from spring 2026 until at least November 2026. This delay is intended to allow time for completing identity verification for directors and persons with significant control (PSC), as well as considering stakeholder feedback.

From November 18, 2025, company directors, LLP members, and PSCs must comply with ECCTA’s identity verification rules.

Companies House has also updated its account filing guidance. The mandatory software filing of accounts and removal of abridged accounts options for small companies remain under review; any changes will be preceded by at least a 21-month notice period.

New instructions have been issued by Companies House regarding how to correct an incorrect date of birth previously filed for a director or PSC.

The revised UK Corporate Governance Code 2024 will apply from January 1, 2026—except Provision 29 on material controls effectiveness declarations, which takes effect a year later. The FRC clarified it does not require early adoption of this provision before January 1, 2026.

The Public Offers and Admissions to Trading (POAT) Regulations 2024 came fully into force on January 19, 2026. This marks a significant change in UK capital markets regulation following extensive consultation efforts aimed at improving market efficiency and attractiveness. Concurrently implemented were new Financial Conduct Authority (FCA) Prospectus Rules replacing previous regulations along with amendments to Market Conduct sourcebook and UK Listing Rules (UKLRs). The FCA has provided updated forms and technical notes reflecting these changes.

Administrative updates were made by the London Stock Exchange through Market Notice N01/26 regarding Admission and Disclosure Standards after POAT regime implementation. Applications for further issues of securities still need submission to the Exchange but not separately for Official List admission.

Revisions were also made to AIM Rules via AIM Notice 61 due to POAT regime changes; further substantive updates are expected in the first half of 2026.

FTSE Russell is consulting on reducing free float requirements in its FTSE UK Index Series from 25% to 10% for non-UK incorporated companies—a move aligning with UKLR minimums—and eliminating distinctions between local/non-local incorporations. This follows previous methodology changes implemented in September 2025 as part of ongoing reforms aimed at boosting London’s listing competitiveness. Consultation closes February 26, 2026.

The Exchange introduced Private Securities Market Rules for PISCES—a new platform enabling private company securities trading intermittently through auctions—following FCA approval as operator in August 2025. While trading has yet to begin actively on this platform, relevant rule books have already been updated effective September 2025.

The Department of Business and Trade stated it will not consult on a proposed Audit Reform and Corporate Governance Bill mentioned in the King’s Speech but emphasized prioritizing corporate reporting simplification while aiming eventually to establish FRC as a statutory regulator when parliamentary time allows.

The FCA launched Enforcement Watch newsletter providing insights from enforcement activities after publishing revised enforcement policy; three investigations into listed issuers have been confirmed following company announcements. Additionally, Mr Russel Gerrity was fined £309,843 by FCA for insider trading while consulting publicly traded oil/gas firms.

The FRC confirmed final signatories under the UK Stewardship Code 2020—291 organizations representing £57.3 trillion assets—prior to transition toward Stewardship Code 2026 effective January 1st this year with existing signatories maintaining status during transition if renewing applications within this period.

A consultation by FCA proposes mandatory climate disclosures aligned with anticipated UK Sustainability Reporting Standards S2 beginning January 1st 2027; Scope 3 emissions can continue under ‘comply or explain’ basis initially while broader sustainability disclosures face similar transitional reliefs delaying full compliance up two years depending on type.

Separately responding to consultations on sustainability assurance oversight regime development started June 2025—the government plans future legislation but meanwhile tasked FRC with creating interim voluntary practitioner register by mid-2026.



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