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

Need to know — Government publishes new company reporting requirements for private and public companies in response to its consultation on Corporate Governance Reform

21 Jun, 2018

The Companies (Miscellaneous reporting) Regulations 2018 (the draft Regulations) have been laid before Parliament and make the legal changes necessary for the Government’s package of corporate governance reforms announced by the Department for Business, Energy and Industrial Strategy (BEIS) in August 2017.

Governance in brief — BEIS issues legislation to deliver key corporate governance reforms

20 Jun, 2018

The Companies (Miscellaneous Reporting) Regulations 2018 have been laid before Parliament. These represent the legislative strand of the Government’s package of corporate governance reforms announced by BEIS in August 2017.

BEIS issues legislation to deliver key corporate governance reforms on pay and stakeholder engagement

11 Jun, 2018

The Companies (Miscellaneous Reporting) Regulations 2018 have been laid before Parliament. These represent the legislative strand of the Government’s package of corporate governance reforms announced by BEIS in August 2017.

Robert Bruce interviews — Paul George, Executive Director, Corporate Governance and Reporting at the Financial Reporting Council

12 Apr, 2018

In a wide-ranging video interview Paul George talks to Robert Bruce about the responses to the recent Corporate Governance Code consultation and areas of challenge in governance generally, what the FRC would like to see more of from strategic reports and information on directors’ responsibilities, what it would like to happen with IFRS post-Brexit, and how the Stewardship Code needs to evolve.

FRC publishes Strategy for 2018/21

27 Mar, 2018

The Financial Reporting Council (FRC) has published its three year strategy for 2018/21 and its budget and levy proposals for the 2018/19 financial year.

GAAP 2018: Model annual report and financial statements for UK listed groups

01 Feb, 2018

GAAP 2018 Model annual report and financial statements for UK listed groups provides comprehensive guidance on the presentation and disclosure requirements for company reporting that will apply to listed groups for 2017/18.

FRC reminds Boards of companies in the construction and business support services sectors of their reporting obligations

30 Jan, 2018

The Financial Reporting Council (FRC) has published reminders to Boards of companies in the construction and business support services sectors of their reporting obligations. Although the FRC guidance is directed at one sector, in the light of the collapse of Carillion, the FRC states it is also relevant to other companies.

FRC publishes Strategy for 2018/21

19 Dec, 2017

The Financial Reporting Council (FRC) has published its three year strategy for 2018/21 and its draft budget and levy proposals for the 2018/19 financial year.

FRC to delay finalisation of Strategic Report guidance

04 Dec, 2017

The Financial Reporting Council (FRC) has today announced that it is to delay the publication of its amended Guidance on the Strategic Report (“the Guidance”) until after the government has announced its legislative changes in respect of reporting on section 172.

FRC’s Financial Reporting Lab issues report on risk and viability reporting

28 Nov, 2017

The Financial Reporting Council’s (FRC’s) Financial Reporting Lab (“the Lab”) has published a report on risk and viability reporting. The report seeks to understand the views of companies and investors participating in the project on the key attributes of principal risk and viability reporting, their value and use. The report also provides illustrative examples of the types reporting that investors favour in this area.

Accounting Roundup - Closing Out 2017

27 Nov, 2017

Closing out 2017 discusses the significant corporate reporting issues relevant to 31 December 2017 annual reports, covering areas of regulatory focus identified in the FRC’s Annual Review of Corporate Reporting 2016/2017, ESMA’s common enforcement priorities for issuers in the European Union together with developments in reporting standards and areas of investor interest.

Governance in brief — FRC issues advice on annual reports for 2017/18 reporting season

26 Oct, 2017

During October the Financial Reporting Council (FRC) issued its 2016/17 Annual Review of Corporate Reporting and its annual letter to FTSE 350 finance directors and audit committee chairs. This edition of Governance in brief explores the findings in the Corporate Reporting Review (CRR) annual report, the recommendations in the FRC’s year-end advice letter to preparers and the aspects of financial statements and broader corporate reporting that the FRC is looking to companies to focus on in the coming year.

We comment on the FRC's consultation - Draft amendments to Guidance on the Strategic Report - Non-financial reporting

23 Oct, 2017

We have published our comment letter on the Financial Reporting Council's (FRC's) consultation on amendments to its Guidance on the Strategic Report.

Deloitte Comment Letter on the FRC's consultation - Draft amendments to Guidance on the Strategic Report - Non-financial reporting

23 Oct, 2017

We have published our comment letter on the Financial Reporting Council's (FRC's) consultation on amendments to its Guidance on the Strategic Report.

FRC publishes findings on the quality of corporate reporting in 2016/2017

23 Oct, 2017

The Financial Reporting Council (FRC) has published its Annual Review of Corporate Reporting 2016/2017, 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.

FRC publishes year-end advice to preparers in advance of the 2017/18 reporting season

11 Oct, 2017

The Financial Reporting Council (FRC) has published a letter to Audit Committee Chairs and Finance Directors, in advance of the 2017/18 reporting season, highlighting changes to reporting requirements and aspects of annual reports where the FRC feels that companies can improve.

Annual report insights 2017 — Surveying FTSE reporting

03 Oct, 2017

Our latest annual reporting survey, 'Annual report insights 2017' provides insights into narrative and financial reporting trends for UK listed companies, together with ideas to help them improve their annual reports. Hot topics including Brexit disclosures, governance reform and integrated reporting are all addressed.

Governance in brief — FRC encourages broader reporting of company purpose and impact in proposed revisions to the Guidance on the Strategic Report

11 Sep, 2017

The FRC has published proposed revisions to its Guidance on the Strategic Report. These revisions encourage companies to report on broader matters that may impact the value and sustainability of business over the longer term and reflect new corporate reporting requirements arising from changes to the Companies Act 2006 which implement the EU Non-Financial Reporting Directive.

Need to know — FRC publishes consultation on amendments to its Guidance on the Strategic Report

30 Aug, 2017

This edition of Need to Know outlines the FRC's consultation on amendments to its Guidance on the Strategic Report.

FRC proposes amendments to its Guidance on the Strategic Report

15 Aug, 2017

The Financial Reporting Council (FRC) has today published, for consultation, amendments to its ‘Guidance on the Strategic Report’ ("the Guidance").The Guidance remains non-mandatory with a view to encouraging best practice.

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