This week:
FCA sets out roadmap for listed company sustainability reporting
The Financial Conduct Authority (FCA) has published Policy Statement PS26/19, in which it has set out the new rules under which companies listed in the UK will be required to disclose against the UK Sustainability Reporting Standards (UK SRS).
The new regime replaces the previous requirement for listed companies to disclose against the Recommendations of the Taskforce on Climate-related Financial Disclosures (TCFD), which was disbanded in 2023.
The FCA had originally proposed comply or explain reporting under UK SRS S1, but mandatory disclosure under UK SRS S2. However, following feedback to its consultation, disclosure under the new regime will now operate across all components of UK SRS on a comply or explain basis.
The new regime will apply to accounting periods beginning on or after 1 January 2027, with first reporting from 2028, although companies may begin reporting earlier on a voluntary basis. However, companies will be able to take advantage of a one-year relief from Scope 3 disclosures and a two-year relief from UK SRS S1 disclosures.
Alongside this, the FCA is seeking views (via Primary Market Bulletin 66) on a new technical note (TN 803.1) on disclosures under UK SRS. The new note will set out the FCA’s expectations regarding the level of detail expected of issuers when preparing disclosures, including when choosing to explain (rather than comply).
Read FCA Policy Statement PS26/19 (opens PDF)
Read FCA Primary Market Bulletin 66
FRC publishes mythbuster on cyber controls
The Financial Reporting Council (FRC) has published a new mythbuster for companies on reporting on cyber security, particularly in light of UK Corporate Governance Code Provision 29.
Provision 29 requires a company’s directors to (among other things) confirm in the company’s annual report that the company’s material controls are effective as at its balance sheet date.
The FRC notes that cyber security is a significant issue for companies, and that many companies will attribute material controls to cyber security. It recommends that companies keep their cyber risks, controls and resilience arrangements under regular review, adapting them as the threat landscape and their own exposure change.
The guidance also acknowledges that some companies are concerned that reporting on cyber controls may entail disclosing commercially sensitive information. It notes that reporting on cyber should not disclose specific technical controls used to prevent or mitigate cyber harm.
The FRC also acknowledges concerns that a subsequent cyber incident could call into question the effectiveness of a company’s earlier effectiveness declaration. The guidance notes that reporting on cyber, including under Provision 29, does not guarantee that a company will not subsequently experience a cyber incident.
Read the FRC’s mythbuster on reporting on cyber security and controls (opens PDF)
Other items
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Corporate reporting. The Financial Reporting Council (FRC) has published its annual review of corporate reporting for 2025/2026. The review assesses financial reporting of FTSE 350 companies during the year, focussing on cash flow statements, financial instruments, impairment of assets, fair value measurement and revenue.
Access the FRC’s annual review of corporate reporting for 2025/2026 (opens PDF)
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Primary Market Bulletin 66. The Financial Conduct Authority (FCA) published Primary Market Bulletin (PMB) 66, in which it confirms it is proceeding with changes (on which it consulted in PMB 63) to its Technical Note 619 to allow issuers, in some cases, to rely on financing under uncommitted facilities for the purposes of giving a clean working capital statement.
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Right to work checks. From 1 October 2026, the scope of right to work check obligations will expand to cover workers’ contracts, subcontracting chains and online matching services. Organisations higher up a contractual supply chain may face liability for illegal working, even without a direct relationship with the worker. Existing commercial contracts and outsourcing arrangements may need to be reviewed.
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