Narrative reporting areas of focus

Regulatory messages continue to emphasise the need for authentic, balanced and comprehensive disclosures in annual reports to satisfy the needs of investors. To achieve this, information in the annual report should be integrated and connected between the strategic report and the rest of the annual report.

In its Annual Review of Corporate Reporting 2022/23, the Financial Reporting Council (FRC) indicates that aside from climate-related reporting requirements, no substantive challenges were raised in relation to non-financial reporting disclosures such as Streamlined Energy and Carbon Reporting (SECR) and it observed that entities may be becoming more familiar with these newer requirements.

However the FRC continues to raise challenges as to whether the strategic report is fair, balanced and comprehensive, noting that the financial review should address not only financial performance but also significant changes to the financial position of the company (i.e. the balance sheet) and significant movements in the cash flow statement.  In the current uncertain economic environment, the FRC particularly expects companies to use the strategic report to articulate clearly the risks and uncertainties the business faces covering economic and other risks such as inflation, together with mitigation strategies and any effects on the strategy and business model. These discussions should be consistent with disclosures made in the financial statements, particularly regarding sensitivities, assumptions and sources of uncertainty.  The FRC encourages companies to refer to its Guidance on the Strategic Report and What Makes a Good Annual Report and Accounts publication, which provides principle-based guidance when preparing a strategic report.

The FRC also noted that several companies, including large private companies, did not produce a section 172 statement which is a requirement for all companies except those that qualify as small or medium-sized.  Financial Reporting Lab report sets out what investors are looking for in this area and how companies can improve their reporting to better meet investor needs.  

Below is a collection of resources on narrative reporting areas of focus.  Click for direct access to specific narrative reporting resources:

Related Resources

Deloitte comment letter on the FCA’s consultation paper 20/3 'Proposals to enhance climate-related disclosures by listed issuers and clarification of existing disclosure obligations '

02 Oct, 2020

We have published our comment letter on FCA’s consultation paper 20/3 Proposals to enhance climate-related disclosures by listed issuers and clarification of existing disclosure obligations (“the CP”).

We comment on the FCA’s consultation paper 20/3 'Proposals to enhance climate-related disclosures by listed issuers and clarification of existing disclosure obligations '

02 Oct, 2020

We have published our comment letter on FCA’s consultation paper 20/3 Proposals to enhance climate-related disclosures by listed issuers and clarification of existing disclosure obligations (“the CP”).

Financial Reporting Lab calls for participants in a new Lab project: reporting on stakeholders and Section 172 disclosures

13 Jul, 2020

The Financial Reporting Lab has called on investors and companies to participate in a new project on corporate disclosures on stakeholders, including statements in response to Section 172 of the Companies Act.

The Climate Financial Risk Forum publishes its guide to help the financial industry address climate-related financial risks

08 Jul, 2020

The Climate Financial Risk Forum (CFRF, jointly established in March 2019 by the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA)) has published an industry guide addressing climate-related financial risks.

FRC updates its COVID-19 guidance for companies to include reporting of exceptional items and APMs

20 May, 2020

The Financial Reporting Council (FRC) has updated its COVID-19 guidance for companies to explain how they should report exceptional items and alternative performance measures (APMs) in their reports and accounts in light of COVID-19.

FRC issues editorial updates to the 2018 Guidance on the Strategic Report

14 May, 2020

The Financial Reporting Council (FRC) has issued editorial updates to Appendix II and Appendix III of its 2018 Guidance on the Strategic Report .

FRC updates its COVID-19 guidance for companies to include going concern considerations for interim reporters

14 May, 2020

The Financial Reporting Council (FRC) has updated its COVID-19 guidance for companies to include considerations for those preparing interim reports.

The new section 172(1) statement – observations from first reporters

29 Apr, 2020

This survey presents a picture of how the first wave of December year-end reporters have approached the new section 172(1) statement. It examines emerging practices and provides some example disclosures.

ICAEW webinar on SECR reporting

02 Apr, 2020

The Institute of Chartered Accountants in England and Wales (ICAEW) will be hosting a webinar providing an overview of the Streamlined Energy and Carbon Reporting (SECR) regulations.

FRC, FCA and PRA issue Covid-19 guidance for companies and auditors

26 Mar, 2020

The Financial Conduct Authority (FCA), Financial Reporting Council (FRC) and Prudential Regulation Authority (PRA) have published a joint statement relating to the impact of Covid-19 on financial reporting.

European Lab seeks members for its second task force

13 Mar, 2020

The European Financial Reporting Advisory Group (EFRAG) has published a call for candidates for members of a new project task force on reporting of non-financial risks and opportunities and linkage to the business model.

FCA issues consultation paper proposing improvements to climate-related disclosures for listed companies

09 Mar, 2020

The Financial Conduct Authority (FCA) has published a consultation paper (CP20/3) which proposes to enhance climate-related disclosures by companies with a UK premium listing and clarify existing disclosure obligations.

FRC issues advice to companies and auditors on coronavirus risk disclosures

18 Feb, 2020

The Financial Reporting Council (FRC) has today published guidance for companies on disclosure of risks and other reporting consequences arising from the emergence and spread of Coronavirus (COVID-19).

ICAEW UK GAAP update webinar

22 Jan, 2020

The Institute of Chartered Accountants in England and Wales (ICAEW) will be hosting a webinar outlining latest developments and implementation issues in UK GAAP and also recent changes to reporting regulations.

Accounting Roundup - Closing Out 2019

10 Dec, 2019

Closing Out 2019 discusses the significant corporate reporting issues relevant to 31 December 2019 annual reports, covering areas of regulatory focus identified in the FRC’s Annual Review of Corporate Reporting 2018/2019 and the ESMA’s common enforcement priorities for issuers in the European Union, together with other developments in reporting standards and areas of investor interest.

Governance in brief — FRC issues advice on annual reports for 2019/20 reporting season

14 Nov, 2019

The FRC has issued its Annual Review of Corporate Reporting and annual open letter to finance directors and audit committee chairs covering its perspectives on key developments and areas of focus for 2019/20 annual reports. The report sets out the FRC’s “expectations for corporate reporting to improve trust in business”, emphasising the annual report is a vehicle of trust and stewardship.

Need to Know - New reporting requirements for large private companies

31 Oct, 2019

This Need to Know addresses the new reporting requirements for large private companies in annual reports for periods commencing on or after 1 January 2019 under the Companies (Miscellaneous Reporting) Regulations 2018 (SI 2018/860).

FRC publishes findings on the quality of corporate reporting in 2018/2019

30 Oct, 2019

The Financial Reporting Council (FRC) has published its Annual Review of Corporate Reporting 2018/2019, which provides the FRC's assessment of corporate reporting in the UK based on evidence from a variety of sources, including the work of the FRC's own Corporate Reporting Review (CRR) team.

Accountancy Europe recommends revising the EU Non-Financial Reporting Directive

23 Oct, 2019

Accountancy Europe has released a call to action recommending five steps to revise the Non-Financial Reporting Directive and strengthen non-financial reporting requirements in Europe.

Annual report insights 2019 — Surveying FTSE reporting

21 Oct, 2019

Our latest annual reporting survey, Annual report insights 2019, provides insights into practices in annual reporting, focusing on areas where requirements have changed, where regulators are focusing or where innovative practices are emerging.

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