Quarterly Listed Company Update – What's new and what's next?

August 2026

As expected, the Financial Conduct Authority (the "FCA") has confirmed that it will be commencing a review of the Disclosure and Transparency Rules ("DTRs") to consider the value of the current rules for issuers and investors and to explore if changes are needed to make UK public markets more attractive while at the same time maintaining high standards and market integrity. This review builds on the listing regime reforms in 2024 and the prospectus regime reforms earlier in 2026. The FCA plans to publish a public consultation paper on the proposed reforms later in 2026. 

The Chartered Governance Institute ("CGI") has published revised guidance on the proper purpose test applicable to requests to inspect or obtain a copy of a company's register of members. The guidance provides an industry view on what constitutes a "proper purpose" for the purposes of the Companies Act 2006 and includes practical examples. The updated guidance takes into account recent case law developments. The guidance is available for members on the CGI's website.

On 26 May 2026, the Department for Energy Security and Net Zero ("DESNZ") published its Post-Implementation Review of the Streamlined Energy and Carbon Reporting Regulations 2018 ("SECR") which require listed, as well as large private companies and LLPs, to disclose information on their greenhouse gas emissions, energy use and energy efficiency measures.

The review concludes that the SECR framework has largely achieved its principal policy aim of improving transparency on energy use and greenhouse gas emissions, and that its objectives remain broadly appropriate. However, the review recommends some amendments, including (i) aligning SECR definitions and metrics with ISSB, CSRD and TCFD to reduce duplication and improve coherence, (ii) introducing a standardised disclosure template and (iii) assessing digital access options that enhance usability and benchmarking. These areas will be considered as part of the planned 2026 consultation on streamlining energy and emissions reporting.

On 4 June 2026, the London Stock Exchange ("LSE") published AIM Notices 62 and 63, setting out proposed changes to (amongst other things) the AIM Rules for Companies ("AIM Rules"). The proposals give effect to the plans set out in the LSE's Feedback Statement: Shaping the Future of AIM, published in November 2025. The consultation closed on 2 July 2026 and the LSE will review feedback before publishing final rule amendments, which are expected to take effect immediately upon publication. The City of London Law Society and the QCA have published their responses to the consultation (see the CLLS response and the QCA response). For further details see our briefing.

The Government has confirmed that the accounts filing reforms introduced by ECCTA 2023 will proceed, but with a one-year delay. These changes will require all companies to file accounts with Companies House using commercial software in iXBRL format. The reforms, originally scheduled to come into force on 1 April 2027, will now take effect from 1 April 2028, to allow companies and software providers additional time to prepare.

Listed companies should assess the position across their group and begin engaging with their software providers and advisers to ensure readiness. Companies House will be contacting all companies via their registered email addresses to inform them of the changes.

(a)     Provision 29 Mythbuster

Listed companies should now be well prepared for the new Provision 29 internal controls' declaration required under the 2024 UK Corporate Governance Code for accounting years beginning on or after 1 January 2026. The Financial Reporting Council (the "FRC") has published a mythbuster on auditors' responsibilities in relation to Provision 29. The FRC's mythbuster addresses key questions regarding auditors' responsibilities in audits of financial statements where the accompanying annual report contains such a board declaration. The mythbuster is available on the FRC's website and is in addition to the earlier mythbuster that was published on the key questions that are on the minds of stakeholders.

(b)    Guidance on Materiality

The FRC published new guidance to help companies, investors and other users of UK annual reports understand how to apply and assess materiality in the context of corporate reporting.

The guidance answers frequently asked questions on applying materiality in corporate reporting and provides practical tips to assist companies in developing their own processes for applying materiality when preparing annual reports.

(c)     FRC Report on Structured Digital Reporting

On 20 May 2026, the FRC published its latest report on structured digital reporting by UK listed companies, together with an accompanying factsheet. While structured digital reporting is now well established across the UK market, the FRC identified a number of issues, such as an inconsistent levels of tagging, earning per share scaling errors and late filings.

Primary Market Bulletin 64 covered a review of Total Voting Rights ("TVR") disclosures and notifications made by issuers on significant transactions. The FCA recommends that issuers confirm TVR figures clearly, select (where possible) the headline information classification of regulated information as "Total Voting Rights", and use explicit language where the TVR is part of a broader disclosure. The disclosure needs to explicitly state "total voting rights" so that it is searchable via a key word search on the NSM.

In relation to significant transactions, risk disclosures should be tailored to the company and the wording for the board statement must track the prescribed text.

On 14 July 2026, the Dematerialisation Market Action Taskforce ("DEMAT") published its Implementation Plan, setting out recommended steps for the withdrawal of paper share certificates as evidence of ownership title and their replacement with digital share registers before the end of 2027. The Government has accepted all of DEMAT's recommendations and confirmed that it will legislate to mandate that all publicly traded UK companies maintain digital share registers and cease issuing paper share certificates. Legislation is expected to come into force before the end of 2027, with the exact date to be confirmed. The registrars will be heavily involved and, to the extent they have not already done so, listed companies should liaise with their registrars on the process.

There have been a number of non-listed company specific developments published in recent months that you may also be interested in:

(a)    Proposals to prescribe mandatory statement content and introduce financial penalties in relation to Modern Slavery Statements. For further details see our briefing.

(b)    Expanded liability in relation criminal offences by senior managers as a result of section 250 of the Crime and Policing Act 2026, which came into force on 29 June 2026. For further details see our briefing.

(c)     On 19 May 2026, the Commercial Payments Bill was introduced to Parliament and given its first reading in the House of Lords. The Bill contains a package of measures intended to improve commercial payment practices and address the persistent late payment of commercial debts in the United Kingdom. For further details see our briefing.