The FCA, when monitoring compliance with Disclosure Guidance and Transparency Rule (DTR) 6.3 noted instances of:

• Annual financial reports that have been made public via a regulatory announcement, but the report has not been filed on the National Storage Mechanism (NSM). 
• Announcements of annual financial reports that do not contain a statement to indicate that the full report is available on the NSM as required under DTR 6.3.5R(1A)(1)(c).
• Announcements that do not contain a statement indicating the website on which the report is available as required under DTR 6.3.5R(3)(a).

The FCA reminds companies that including links in an announcement to other hosting sites such as the London Stock Exchange’s website to provide access to a pdf of the report without also uploading it to the NSM does not meet the filing requirement in DTR 6.2.10R.

With respect to structured digital reporting, the FCA has identified low compliance rates with preparation and filing that meets the disclosure requirement for annual financial reports.  Examples include:

• Annual financial reports that contain consolidated financial statements that have not been correctly tagged in accordance with DTR 4.1.18R.
• Annual financial reports that have been filed on the NSM in accordance with DTR 6.2.10R but not in XHTML format as required by DTR 4.1.15R.

The FCA reminds companies that it will continue to closely monitor compliance with annual financial reporting obligations and take supervisory action in respect of non-compliance as appropriate.  In order to improve their structured digital reporting, the FCA suggests that companies review the Financial Reporting Lab's December 2023 report on this area.

The Bulletin also highlights a proposed change to ethnicity categories to align with revisions made by the Office of National Statistics (ONS) for those companies in scope of the FCA's diversity disclosure requirements (either through LR LR 9.8.6R(9) or LR 14.3.33R(1)).  It is proposed that the 'other ethinic group' category in the board diversity rules be updated to align with the ONS 'Other ethnic group' category description.  The FCA indicates that any potential change will be made in the summer alongside wider Listing Rule changes.

The Primary Market Bulletin is available on the FCA website.