Recent Developments for UK PLCs — September 2024

Regulators Seek Feedback on the Future of Digital Reporting in the UK

On 13 August 2024, the Financial Reporting Council (FRC), as part of a cross-regulatory group comprising the FCA, Companies House, HMRC and Charity Commission for England and Wales, published a discussion paper on the future of digital reporting in the UK.

This high-level paper addresses recent developments in the regulatory landscape affecting the digital reporting obligations of listed companies and seeks feedback on how to implement policy changes. Key topics include the following:

• Potential alternatives to the European Single Electronic Format (ESEF) taxonomy — which companies admitted to UK regulated markets are required to use to satisfy their obligations to prepare their annual financial reports in a “structured digital format”
• Proposed changes or extensions to structured digital reporting (such as different approaches to the detailed tagging of notes to financial statements) to support regulatory disclosure initiatives
• Considerations around imposing requirements to obtain assurance from independent third parties that the digital tagging of financial statements are compliant with the reporting requirements
• The impact of requirements on companies and charities to digitally tag the full scope of information in financial statements
• Strategies to support stakeholders in adapting to new digital reporting requirements

The discussion paper seeks input from various stakeholders, including listed companies. The deadline for submitting responses is 1 November 2024.

More Comprehensive Metadata Requirements for Submissions to the National Storage Mechanism

On 9 August 2024, the FCA launched a consultation (CP24/17) on proposals to enhance the National Storage Mechanism (NSM), the FCA’s online free-to-use archive of company information. The proposals seek to improve the NSM’s data quality controls and make it easier for NSM users to find regulated information.

Amongst other things, the FCA proposes to introduce more comprehensive metadata requirements for listed companies when submitting NSM filings:

• Listed companies filing regulated information would need to notify the legal entity identifiers (LEIs) of the person filing the regulated information and any related issuers that are the subject to the disclosure.
• The FCA proposes updates to the headline codes and categories that listed companies would need to use to categorise regulated information submitted to NSM.

The consultation closes on 27 September 2024 and the FCA expects the new metadata requirements to come into force in H2 2025.