United Kingdom | Publication | July 2025
This checklist is intended to help UK-listed companies keep abreast of key developments in the fast-moving areas of corporate governance and narrative reporting.
It sets out our thoughts on some of the main areas of change during the last few months, as well as a list of key developments by area, including links to more detailed summaries of those developments.
In the period covered by this checklist, we have seen the implementation of legislation which impacts company reporting. As well as changes to the company size thresholds aimed at reducing the reporting burden on certain companies, quoted companies will be interested in the changes to the reporting requirements relating to future directors’ remuneration reports. The updated GC100 and Investor guidance on director remuneration reporting, which reflects both the changing legislative requirements and evolving best practice in this area, is likely to be particularly helpful in looking to meet the new reporting requirements.
The number of publications in this period concerned with climate-related and sustainability reporting reflects the current focus, internationally and in the UK, on this area of reporting. UK regulated financial institutions and FTSE 100 companies are likely to be particularly interested in the current UK government consultation on climate-related transition plans.
FRC: Amendments to FRS 101 Reduced Disclosure Framework – 2024/25 cycle: On 28 May 2025, the Financial Reporting Council (FRC) published the results of its annual review of amendments to IFRS Accounting Standards to decide whether FRS 101 Reduced Disclosure Framework should provide exemptions from new disclosure requirements or whether other consequential amendments are required. These amendments are the outcome of the 2024/25 annual review of FRS 101, which addressed amendments issued in the year to 31 August 2024. Further details are here.
FRC: Updates to reflect company size threshold amendments: On 21 March 2025, the Financial Reporting Council (FRC) published updates to existing publications to reflect changes to UK company size thresholds for corporate reporting purposes which are due to come into effect from 6 April 2025. Further details are here.
FRC: TAC Survey on ISSB's Exposure Draft on Proposed Amendments to the SASB Standards: On 29 July 2025, the Financial Reporting Council (FRC), as secretariat to the UK Sustainability Disclosure Technical Advisory Committee (TAC), published a survey seeking views from stakeholders on the International Sustainability Standards Board (ISSB)’s recently proposed amendments to the Sustainability Accounting Standards Board (SASB) Standards. Further details are here.
ISSB: Comprehensive review of priority SASB Standards and targeted amendments to others proposed: On 3 July 2025, the International Sustainability Standards Board (ISSB) published two exposure drafts proposing amendments to the SASB Standards and consequential amendments to the Industry-based Guidance on Implementing IFRS S2. Further details are here.
DESNZ: Climate-related transition plans – Consultation: On 25 June 2025, the Department for Energy Security and Net Zero (DESNZ) published a consultation seeking views on how the Government could take forward its manifesto commitment which involves mandating “UK-regulated financial institutions (including banks, asset managers, pension funds and insurers) and FTSE 100 companies to develop and implement credible transition plans that align with the 1.5°C goal of the Paris Agreement”. Further details are here.
DBT: Draft UK Sustainability Reporting Standards – Consultation: On 25 June 2025, the Department for Business and Trade (DBT) published a consultation seeking views on draft UK Sustainability Reporting Standards (UK SRS). These are based on IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures published by the International Sustainability Standards Board in June 2023. Further details are here.
DBT: Assurance of sustainability reporting – Consultation: On 25 June 2025, the Department for Business and Trade (DBT) published a consultation seeking views on the Government's proposal for greater regulatory oversight of third-party assurance services for sustainability-related financial disclosures. Further details are here.
IFRS Foundation: Disclosing information about an entity’s climate-related transition, including information about transition plans, in accordance with IFRS S2 – Guidance: On 23 June 2025, the IFRS Foundation published new guidance as part of its commitment to supporting the implementation of IFRS Sustainability Disclosure Standards (ISSB Standards). The document builds on disclosure-specific material developed by the Transition Plan Taskforce (TPT), for which the IFRS Foundation took responsibility in 2024 to reduce fragmentation in disclosures and enhance the quality and comparability of information provided by entities applying the requirements in IFRS S2. Further details are here.
FRC: Proposed International Standard on Sustainability Assurance (ISSA) (UK) 5000 General Requirements for Sustainability Assurance Engagement – Invitation to comment: On 29 May 2025, the Financial Reporting Council (FRC) published a consultation paper on a proposed UK version of the International Standard on Sustainability Assurance (ISSA) 5000, “General Requirements for Sustainability Assurance Engagements” (Consultation). Further details are here.
TNFD: Asking better questions on nature – Guide for directors: On 6 May 2025, the Taskforce on Nature-related Financial Disclosures (TNFD) published a guide designed to help board members surface the decision-useful information they need to ensure that nature-related issues are being appropriately incorporated into their company’s governance, strategy, risk management and capital allocation decision making. Further details are here.
ISSB: Exposure Draft proposing targeted amendments to IFRS S2 to ease application for companies published: On 28 April 2025, in response to market feedback, the International Sustainability Standards Board (ISSB) published an Exposure Draft proposing targeted amendments to IFRS S2 Climate-related Disclosures that would provide reliefs to ease application of requirements related to the disclosure of greenhouse gas (GHG) emissions. Further details are here.
QCA: New Boardroom Guides published – Audit, Remuneration and Nomination Committee Guides: On 1 July 2025, the Quoted Companies Alliance (QCA) published three new board committee guides to accompany the QCA Environmental and Social Guide published in December 2024. Further details are here.
FRC: New UK Stewardship Code 2026 published: On 3 June 2025, the Financial Reporting Council (FRC) published an updated Stewardship Code, the UK Stewardship Code 2026, following a consultation process that ran from November 2024 to February 2025. It will apply from 1 January 2026 and replace the UK Stewardship Code 2020. Further details are here.
IoD: Commission to explore the evolving role of non-executive directors in the UK launched: On 10 April 2025, the Institute of Directors (IoD) announced the launch of a Commission to address the unique challenges faced by non-executive directors (NEDs) and help them unlock their full potential. Further details are here.
FRC: Wates Principles insights – Roundtable invitations: On 2 April 2025, as part of its work in overseeing the Wates Principles, the Financial Reporting Council (FRC) announced that it wants to gather insight from private companies on their decision-making processes when choosing which governance framework to adopt. Further details are here.
FCA: Handbook Notice No 128 – Corporate Governance Code changes: On 28 March 2025, the Financial Conduct Authority (FCA) published Handbook Notice No 128 which, among other things, confirms changes to the UK Listing Rules (UKLRs) and Disclosure and Transparency Rules (DTRs) following a consultation in CP24/26. These changes stem from theCorporate Governance Code (Amendment) Instrument 2025. Further details are here.
Parker Review: FAQs on the extension of scope to encompass senior management – Guidance: In June 2025, the Parker Review Committee published updated guidance, in the form of Frequently Asked Questions (FAQs), for use by those companies that need to prepare data for reporting to the Parker review on their senior management in December 2025. Further details are here.
DBT: FTSE Women Leaders Review – Achieving Gender Balance: On 25 February 2025, the Department for Business and Trade (DBT) announced the publication of the latest FTSE Women Leaders Review report which reports on the progress by FTSE 350 companies and the 50 largest UK private companies in increasing women in senior leadership positions and on their boards. This builds on the earlier work of the Davies Review and the Hampton-Alexander Review. Further details are here.
ISS: Launch of annual global benchmark policy survey: On 25 July 2025 Institutional Shareholder Services (ISS) launched its annual global benchmark policy survey. This is a key element of its annual policy development process for potential policy changes for 2026 and beyond. Further details are here.
PIRC: Shareholder Voting Guidelines 2025: PIRC has published its latest UK Shareholder Voting Guidelines. PIRC applies these to all listed companies, including overseas companies, that it covers on the UK market. Further details are here.
Home Office: Transparency in supply chains – Revised guidance published: On 25 March 2025 the Home Office published a revised version of its statutory guidance ‘Transparency in supply chains: a practical guide’. This was first published in October 2015 and has been revised over time since then. Further details are here.
DBT: Late payments consultation –Tackling poor payment practices: On 31 July 2025, the Department for Business and Trade (DBT) published a consultation document seeking views on a package of legislative measures aimed at addressing late payments, and ensuring businesses are paid fairly and on time. Further details are here.
FRC: Opportunities for future UK digital reporting – Feedback Statement: On 15 May 2025, the Financial Reporting Council (FRC) published a Feedback Statement summarising its responses to the Discussion Paper “Opportunities for Future UK Digital Reporting”, which was issued on 13 August 2024 and closed on 1 November 2024 (see further here). Further details are here.
FRC: Structured digital reporting – 2024/25 insights: On 28 April 2025, the Financial Reporting Council (FRC) published its annual review of structured digital reporting, highlighting key areas for improvement in how UK listed companies present their digital annual reports. Further details are here.
Office for Equality and Opportunity; Equality (Race and Disability) Bill – Mandatory ethnicity and disability pay gap reporting – Consultation: On 18 March 2024, the Office for Equality and Opportunity published an online consultation seeking views on how to introduce mandatory ethnicity and disability pay reporting for large employers (those with 250 or more employees). Responses to the consultation will help to shape proposals to be included in the Equality (Race and Disability) Bill, which was announced in the King’s Speech in July 2024. Further details are here.
DBT: Duty to report: Guidance to reporting on payment practices and performance updated: On 5 March 2025, the Department for Business and Trade (DBT) published updated Guidance on the duty on the UK’s largest companies and limited liability partnerships (LLPs) to report on a half-yearly basis on their payment practices, policies and performance during their financial year. Further details are here.
FRC: Guidance on the Going Concern Basis of Accounting and Related Reporting (including Solvency and Liquidity Risks): On 25 February 2025, the Financial Reporting Council (FRC) published updated 'Guidance on the Going Concern Basis of Accounting and Related Reporting, including Solvency and Liquidity Risks' (Guidance). This provides guidance on the going concern basis of accounting for all companies, including those that apply the UK Corporate Governance Code, as well as guidance on the reporting of solvency and liquidity risks. Further details are here.
GC100 and Investor Group: Directors’ Remuneration Reporting Guidance: On 5 June 2025, theGC100 and Investor Group (Group) published updated Directors' Remuneration Reporting Guidance (Guidance). First published in 2013, and most recently updated in 2019, the Guidance is designed to assist companies in complying with key elements of the different regulations relating to remuneration reporting. Further details are here.
DBT: The Companies (Directors’ Remuneration and Audit) (Amendment) Regulations 2025 – Guidance Note: On 23 April 2025, the Department for Business and Trade (DBT) published a Guidance Note to accompany The Companies (Directors’ Remuneration and Audit) (Amendment) Regulations 2025 (Regulations). Further details are here.
The Companies (Directors' Remuneration and Audit) (Amendment) Regulations 2025: On 3 April 2025, The Companies (Directors' Remuneration and Audit) (Amendment) Regulations 2025 and accompanying Explanatory Memorandum were laid before Parliament, and they came into force on 11 May 2025. Further details are here.
Risk Coalition: Raising your game - Guidance to enhance risk governance, risk-taking, resilience and reporting: On 21 February 2025, the Risk Coalition, a network of not-for-profit professional bodies and membership organisations committed to raising the standards of risk governance, published new cross-sector guidance for boards and their committees with consolidated risk responsibility (whether a dedicated risk committee or an audit and risk committee). Further details are here.
Publication
In <em>V & Anor v K</em> [2025] EWHC 1523 (Comm), the Commercial Court has dismissed jurisdictional and serious irregularity challenges under sections 67 and 68 of the Arbitration Act 1996 arising out of an LMAA arbitration.
Publication
The recent Singapore High Court decision in <em>The “CHLOE V” [2025] SGHC 142</em> explores the legal and commercial tensions that arise at the intersection of ship finance, charterparty negotiations, and mortgagee enforcement rights.
Publication
The ‘Omnibus package’ is due to be negotiated by the European Parliament and the Council. When initially published by the European Commission on 26 February 2025 (see our previous publication on this here), the Omnibus instantly drew attention in light of the significant changes it sought to introduce to the EU Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D).
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