EQ Monthly Bulletin - April 2026

In This Edition:

1. Gender Diversity in AIM Company Boards Report
2. Department for Business and Trade – Statutory Guidance for Companies and LLPs on the meaning of “Significant Influence or Control” under the PSC Regime
3. FCA Quarterly Consultation Paper No. 51 – Prospectus Rules: Admission to Trading on a Regulated Market Sourcebook and the UK Listing Rules
4. Parker Review Committee – Annual Report
5. Home Office – Call for Evidence – Economic Crime Information Sharing
6. FRC – Comply or Explain Guidance
7. Employment Rights Act 2025 – Requirement for Companies to Develop and Publish an Equality Action Plan
8. Department for Business and Trade – Late Payment of Invoices Consultation Response
9. Department for Business and Trade Consultation – Implementation of a Corporate Re-domiciliation Regime
10. HM Treasury – Draft Money Laundering and Terrorist Finance (Amendment) Regulation 2026
11. Gov.uk – Consultation Response - Mandatory Ethnicity and Disability Pay Gap Reporting

Gender Diversity in AIM Company Boards Report

On 26 February 2026, Indigo Independent Governance and Addidat published their fourth annual Gender Diversity in AIM Company Boards report. 
The data shows that:

• Female directors on AIM boards remains at 16%
• 38% of AIM boards are all-male, an increase of 1.4% over last year
• Only 11% of firms would meet the 40% women on boards threshold expected of FTSE350 companies

The full report is available to view here: Gender diversity in AIM company boards fourth annual report 2026

Department for Business and Trade – Statutory Guidance for Companies and LLPs on the meaning of “Significant Influence or Control” under the PSC Regime

On 4 March 2026, the Department for Business and Trade (DBT) published its statutory guidance for companies and for LLPs on the meaning of "significant influence or control" under the PSC regime. The publication of this guidance follows the DBT's publication of draft guidance in January 2026 which made changes to reflect the abolition of the requirement for companies and LLPs to maintain a local PSC register.

The guidance has been published under the power to revise existing guidance conferred by paragraph 24(9) of Schedule 1A to the Companies Act 2006 (as applied, in the case of LLPs, by regulation 31M of the Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009 (SI 2009/1804)). 
 No substantive amendments have been made to the draft versions.

For PSC Statutory Guidance – Companies see this link: Statutory guidance on the Meaning of “Significant Influence or Control” over Companies in the Context of the Register of People with Significant Control

PSC Statutory Guidance for Companies webpage is available here: People with significant control: 2026 company statutory guidance - GOV.UK

For PSC Statutory Guidance for LLPs see this link: Statutory Guidance on the Meaning of “Significant Influence or Control” over Limited Liability Partnerships in the Context of the Register of People with Significant Control

PSC Statutory Guidance for LLPs webpage is available here: People with significant control: 2026 LLP statutory guidance - GOV.UK

FCA Quarterly Consultation Paper No. 51 – Prospectus Rules: Admission to Trading on a Regulated Market Sourcebook and the UK Listing Rules

On 6 March 2026, the FCA published Quarterly Consultation Paper No 51 (CP26/8) in which it consults on proposed amendments to the Prospectus Rules: Admission to Trading on a Regulated Market sourcebook (PRM) and the UK Listing Rules (UKLR). 

PRM amendments

The amendments to the PRM are intended to clarify certain rules and to give proper effect to policy proposals set out in Consultation Papers CP24/12 and CP25/2 and finalised in Policy Statement PS25/9. These include amendments to:

• PRM 1.4.12R - which provides an exemption from the prospectus requirement for admissions to trading of transferable securities which are offered, allotted or to be allotted to existing or former directors or employees
• The requirement in PRM 9.5.2R for an IPO prospectus to be published at least three working days prior to the end of the offer period, to clarify that it applies only where there is retail participation 
• PRM 8.2.3R - to remove the requirement to repeat a content-specific accompanying statement for a protected forward-looking statement more than once in a prospectus
• Remove the requirement for cross-reference lists to be included in the no change confirmation letter provided by issuers under PRM 9.2.16R
• Cross references and terminology within the PRM to ensure clarity and consistency 

ULKR amendments

The amendments to the UKLR would remove UKLR 6.4.4R(4) which requires issuers to notify a Regulatory Information Service (RIS) of any new issue of equity securities or a public offering of existing equity securities. The notification requirement in PRM 1.6.4R which requires issuers to notify a RIS of the admission to trading of new securities would be retained.

The consultation on changes to the UKLR closed on 23 March 2026, the consultation for the changes to the PRM closed on 20 April 2026.

The FCA’s consultation paper is available to view here: CP26/8: Quarterly Consultation Paper No. 51

Parker Review Committee – Annual Report

On 9 March 2026, the Parker Review Committee published its 2026 annual report on progress against targets set for the numbers of ethnic minority directors on boards and in senior management. The report uses data as of December 2025 collected through a voluntary census.

The Review found that there is steady progress across the FTSE 350 of ethnic minority representation at board level but a notable variation between different ethnic groups, suggesting that existing measures may not be addressing underlying barriers. 
Senior management representation is slightly higher than for the previous year, but it notes that considerable progress is needed to meet the 2027 targets set by the companies themselves.

The annual report states that:

• In the FTSE 100, 98 companies (an increase of three from 2024) met the target of having at least one ethnic minority director
• In the FTSE 250, 205 companies (89%) of the 231 who provided data met the target of having at least one ethnic minority director (an increase of one from 2024)
• In respect of the 50 UK private companies in scope, the target is to have at least one ethnic minority director on the board by December 2027.  Of these 50 companies, data was received from 36 in December 2025.  Of the 36 companies, 21 have met the target, which is 58% of companies which responded and 42% of the total 50.

The report can be accessed here: The Parker Review March 2026

Home Office – Call for Evidence – Economic Crime Information Sharing

On 9 March 2026, the Home Office published a call for evidence on economic crime information sharing.  This refers to the provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) to ensure the full potential of information sharing is realised.

This Call for Evidence marks the beginning of a strategic effort to reform the UK’s information-sharing framework for economic crime, to inform future policy development and make any required improvements to the legal and operational framework for economic crime information sharing.

The call for evidence closes on 18 May 2026.

Further information can be found here: Call for Evidence: Economic Crime Information Sharing

FRC – Comply or Explain Guidance

On 16 March 2026 the FRC published updated guidance to assist investors, proxy advisors and other users of corporate reports to understand 'comply or explain' reporting used by companies departing from provisions under the UK Corporate Governance Code.

The guidance notes that the principles set out in the Code are simple and high level and they provide companies with significant discretion when applying them to their circumstances.   
The guidance also explains that, when applying the provisions in the Code which support the principles, companies should:  

• Embrace the flexibility offered by those provisions, apply the governance arrangements that are most suitable to their circumstances and clearly explain any departures from the Code 
• Be transparent about any departures from the Code 
• Use the following five criteria when explaining departures: explain the context and background to the departure, provide a convincing rationale for the approach taken, describe any risks and mitigating actions, explain if and when the company intends to comply, and ensure that their explanations are understandable and persuasive

The updated guidance is available here: Improving the quality of ‘comply or explain’ reporting

Employment Rights Act 2025 – Requirement for Companies to Develop and Publish an Equality Action Plan

On 16 March 2026, the Employment Rights Act 2025 (Commencement No 2 and Transitional and Saving Provisions) (Amendment) Regulations 2026 were made, bringing into force certain provisions of the Employment Right Act 2025.

Regulation 3 (7) provides that section 33 of the Employment Rights Act will come into force on 6 April 2026, inserting a new section 78A, which provides that future regulations may require companies with more than 250 employees to develop and publish an Equality Action Plan.  

This is voluntary from April 2026 but will become mandatory in spring 2027, although no date has been confirmed.

The full text of the Regulation can be found here: The Employment Rights Act 2025 (Commencement No. 2 and Transitional and Saving Provisions) (Amendment) Regulations 2026

Department for Business and Trade – Late Payment of Invoices Consultation Response

On 24 March 2026, the Department for Business and Trade (DBT) published its response to its consultation requesting views on proposed legislative measures to address late payment of invoices. 

The government intends to take various measures, including the following, that are relevant to financial reporting:

• Introduce a requirement for boards or audit committees of persistently late-paying large companies to publish commentary on Gov.uk explaining why payment performance is poor, the steps that they are taking to address this, and which actions from previous commentary have not been implemented and why
• Ensuring the Small Business Commissioner (who will be given power to investigate as part of the proposals) writes to company boards and audit committees when assuring payment performance reporting and investigating any other matter regarding a companies’ payment practices
• Amend the Reporting on Payment Practices and Performance Regulations 2017 to make it a requirement for large companies to report on statutory interest payments on late payments

The measures require primary and secondary legislation, timing for which has not been provided.

The DBT consultation response can be found here: Time To Pay Up: Government Response to 2025 Late Payment Consultation

Department for Business and Trade Consultation – Implementation of a Corporate Re-domiciliation Regime

On 25 March 2026, the Department for Business and Trade published a consultation paper seeking views on the implementation of a corporate re-domiciliation regime, enabling foreign-incorporated companies to change their places of incorporation to the UK while maintaining their legal identities.   

Matters on which views are sought include: 

• The principles of the regime, which mostly align with those proposed by the Panel in its October 2024 proposals 
• The appropriate eligibility criteria, which broadly aligns with that proposed by the Panel in 2024. The government does not propose to implement the Panel's suggestion for a reserve power for the Secretary of State to make regulations stopping body corporates applying from certain countries identified as problematic
• The requirement that the proposed directors of the body corporate make a solvency statement based on the requirements for a reduction of capital as set out in the Companies Act 2006
• The extent legislation is required to set out the effects of re-domiciliation 
• The sufficiency of a two-month period for a re-domiciling company to issue and deliver share certificates and the requirement that re-domiciling companies maintain books and records that existed prior to re-domiciling for ten years
• The Panel's considerations on where tax legislation may need to be amended or introduced

The consultation closes on 19 June 2026 and can be viewed here: Corporate re-domiciliation consultation document

HM Treasury – Draft Money Laundering and Terrorist Finance (Amendment) Regulation 2026

On 26 March 2026, HM Treasury published the draft Money Laundering and Terrorist Financing (Amendment) Regulations 2026 and a draft explanatory memorandum, proposing amendments to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs). 

The changes expand and tighten Anti Money Laundering (AML) controls, with a particular focus on cryptoasset businesses, correspondent relationships and changes in control, and reinforce the UK’s broader economic crime and national security objectives. 

The draft Regulations propose:

• Amendments to the MLRs to refine customer due diligence (CDD), enhanced due diligence (EDD) and additional due diligence (ADD) requirements in relation to cryptoasset businesses, unusually complex or large transactions, high risk jurisdictions and pooled client accounts
• Strengthening the AML regime for cryptoasset businesses, by aligning the MLRs with the new financial services regulatory framework for cryptoassets established under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 

The Regulations come into force 21 days after being made, with certain crypto provisions coming into force from February 2027. 

The Regulations can be accessed here: The Money Laundering and Terrorist Financing (Amendment) Regulations 2026

The Explanatory Memorandum is available here: The Money Laundering and Terrorist Financing (Amendment) Regulations 2026

Gov.uk – Consultation Response - Mandatory Ethnicity and Disability Pay Gap Reporting

On 25 March 2026, the government published a response to its consultation on mandatory ethnicity and disability pay gap reporting, indicating widespread support for the government's plans.  It therefore intends to go ahead with introducing mandatory ethnicity and disability pay gap reporting for employers with 250 or more employees.

Employers will be required to publish a binary comparison between the pay of “White”(including “White Other”) employees and the pay of employees in all other ethnic groups. In addition, they will be required to publish comparisons between the pay of employees in the five broad ethnic groups classified by the Office for National Statistics: White, Asian or Asian British, Black, Black British, Caribbean or African, Mixed or multiple ethnic groups and other ethnic groups.

For disability pay gap reporting, employers will only need to publish a binary comparison between the pay of disabled and non-disabled employees, using the Equality Act 2010 definition of disability. 

In respect of both ethnicity and disability pay gap reporting, employers will be required to publish mean and median differences in average hourly rates of pay and bonuses, the percentage of employees in each pay quartile and the percentage of employees receiving bonus pay. Employers will also be required to provide workforce composition data to provide context to their data. 

No timeline for the introduction of mandatory ethnicity and disability pay gap reporting has been provided at this stage and guidance will also be produced in due course.

Further information is available here: Consultation on mandatory ethnicity and disability pay gap reporting: government response - GOV.UK