Certain companies (where qualifying criteria is met) are required to publish additional content in their annual reports following the introduction of The Companies (Miscellaneous Reporting) Regulations 2018 (“the regulations”) which were published on 17 July 2018. The requirements apply to companies whose financial year starts on or after 1st January 2019.
To support the regulations, in December 2018, the Financial Reporting Council (“FRC”) published the new Wates Corporate Governance Principles for Large Private Companies which will aid large private companies in meeting their obligations under the regulations.
Aspire’s summary of reporting requirements;
| Regulation No. | Explanation | Companies in scope |
| 4 | Statement in the strategic report of how directors have had regard to the conditions set out in s172 (1) (a)-(f) of the Companies Act 2006 (“the Act”). You must ensure that the statement is available on the company website. | UK incorporated companies already required to produce a strategic report except those qualifying as medium-sized (see sections 465-467 of the Act) in relation to a financial year.
Company must meet at least 2 of the following;
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| 13 | Statement in the directors’ report summarising how directors have engaged with employees, taken account of their interests and how that regard for employee’s interests has effected principle decisions taken by the company in the financial year | UK incorporated companies with more than 250 employees (parent companies must detail the number of employees in the group and not just the employees employed by the parent company) |
| 13 | Statement in the director’s report summarising how directors have engaged with suppliers, customers and others in a business relationship with the company | UK incorporated companies already required to produce a strategic report except those qualifying as medium-sized (see sections 465-467 of the Act) in relation to a financial year.
Company must meet at least 2 of the following;
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| 14 | Statement in the director’s report about the corporate governance arrangements applied by the company | UK incorporated companies with either:
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| 17 | Publication of the ratio of the CEO’s remuneration to the median, 25th and 75th quartile pay remuneration of their UK employees in the director’s report | Quoted companies with more than 250 UK employees.
“Quoted” as defined by the Companies Act 2006. This means UK incorporated companies who are quoted on the UK Official List, the New York Stock Exchange, NASDAQ or a recognised stock exchange in the European Economic Area. It does not include companies listed on the Alternative Investment Market |
| 18 | Illustration of the effect of future share price increases on executive pay outcomes in the director’s remuneration report | UK Incorporated quoted companies.
See above definition of “quoted” |
There is never a shortage of reporting obligations and the burden on businesses to report more and be more transparent is never relinquished. Please see a summary of additional important reporting requirements that are currently in legislation.
| Reporting Requirement | Explanation | Companies within the scope |
| Gender pay gap reporting(“GPGR”) – The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 | Each year by the 31st March for public sector organisations and 5th April for private and voluntary sector employers, must publish a gender pay gap report containing six calculations which need to be carried out.
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250 or more employees.
A wider definition of ‘employee’ for the purposes of the GPGR is adopted. The GPGR utilises the Equality Act 2010 definition;
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| Modern Slavery Statement – Section 54 of the Modern Slavery Act 2015 | Each financial year, qualifying companies must prepare a ‘slavery and human trafficking’ statement and publish this on their website. The statement may outline;
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Any organisation in any part of a group structure will be required to comply if they;
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| Duty to report on payment practices and performance guide – The Reporting on Payment Practices and Performance Regulations 2017 | Businesses within the scope of the reporting requirement must prepare and publish information about their payment practices and performance in relation to qualifying contracts.
The report must be published on a web-based service provided by government within 30 days of the end of the reporting period and approved by a named company director or designated member.
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If they meet at least two of three thresholds for qualifying as a medium-sized company under the Act;
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It is important to remember that HMRC will not tell you whether you are in the scope of the new reporting requirements. Therefore, it is important to monitor the qualifying criteria regularly to ensure that you know when your company is within the scope of a reporting requirement.
Read the FAQ guide published by the Department for Business, Energy and Industrial Strategy on the reporting requirements, here.