We have published our comment letter on the Government’s consultation on the Reporting on Payment Practices and Performance Regulations 2017 and the Limited Liability Partnerships (Reporting on Payment Practices and Performance) Regulations 2017 (‘the Regulations’).

We agree with the Government’s focus on the importance of responsible payment practices. Since they came into effect, the Regulations have had a recognisable impact in shaping how organisations have implemented prompt payment practices and the organisations that have approached us for advice in this area have taken their reporting obligations seriously. We agree that the Regulations should be extended beyond their current statutory expiration date.

Our response also raises the following observations:

• Reporting the value of payments that have not been paid within agreed terms: we do not think this additional disclosure will deter organisations from making late payment and highlight the risk that this will drive the wrong behaviours, encouraging organisations to prioritise payment of larger value invoices.
• Disclosure in the directors’ report: we do not believe there should be a new requirement for organisations to disclose the information required by the Regulations in their directors’ report as well as in their online submission.

Our full comment letter is available below.

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