EQ Monthly Bulletin - August 2026

In This Edition:

1. EFRAG (European Financial Reporting Advisory Group) – Exposure draft of European Sustainability Reporting Standards for some non-EU Countries
2. Financial Reporting Council – Materiality in Corporate Reporting Report
3. Financial Conduct Authority – Handbook Notice 143
4. London Stock Exchange – New AIM Rules
5. London Stock Exchange – New AIM Rules for Nominated Advisers
6. FCA – Policy Statement – Changes to Information Flows for UK Equity IPOs
7. Companies House – Transition Plan Update
8. FCA – Introducing an Inside Information Declaration when Submitting Documents to the FCA 

EFRAG (European Financial Reporting Advisory Group) – Exposure draft of European Sustainability Reporting Standards for some non-EU Countries 

On 23 July 2026, EFRAG published its consultation on the exposure draft of the European Sustainability Reporting Standards (ESRS) for certain non-EU undertakings (ESRS-40a ED), which it has developed as technical advice to the European Commission.

The ESRS-40a will apply to a subsidiary undertaking or branch with significant activities in the EU whose ultimate parent undertaking is governed by a law of a third country. Subject to it meeting certain reporting thresholds set out in Article 40a of the Accounting Directive, it is required to publish an ESRS-40a sustainability report.

The consultation closes on 31 October 2026 and EFRAG aims to deliver its technical advice to the European Commission in January 2027.

The consultation and further information on EFRAG is available via their website: ESRS for Certain Non-EU Undertakings in Accordance with Article 40a of the Accounting Directive | EFRAG 

Financial Reporting Council – Materiality in Corporate Reporting Report

On 29 July 2026, the FRC published Applying Materiality in Corporate Reporting, providing practical guidance for preparers, investors and other users of annual reports on how materiality should be assessed and applied in corporate reporting. 

Key observations include: 

• Entities may find it helpful to follow a structured materiality process: identify primary users and their information needs; determine potentially material matters; assess materiality using both quantitative and qualitative factors; organise disclosures clearly; review the report as a whole; and refresh assessments annually. 
• Reporting requirements generally only need to be applied where the information is material. Immaterial disclosures should be removed where possible, as they can obscure information that is important to users, subject to any mandatory legal or regulatory requirements. 
• Materiality assessments should focus on the needs of primary users, including shareholders, potential investors, lenders and creditors. Information intended primarily for other stakeholders should generally be reported outside the annual report unless it is also material to primary users. 
• Strong connectivity across the annual report improves understanding. The FRC encourages the consistent use of terminology, metrics and assumptions, supported by cross-referencing.  

The Insights can be viewed here: Applying materiality in corporate reporting

Financial Conduct Authority – Handbook Notice 143

On 31 July 2026, the FCA published Handbook Notice 143 which sets out, among other things, the amendments that have been made to the Prospectus Rules: Admission to Trading on a Regulated Market sourcebook (PRM) by the FCA instrument Prospectus Rules: Admission to Trading on a Regulated Market (Clarificatory Amendments) Instrument 2026, as proposed in their Quarterly Consultation 51 in March 2026.  

The instrument makes changes to give proper effect to aspects of the Public Offers and Admissions to Trading regime, which came into force on 19 January 2026.  

The main amendments are as follows: 

• 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. 
• Remove the requirement to repeat a content-specific accompanying statement for a protected forward-looking statement more than once in a prospectus (with a cross reference being sufficient in other instances) under PRM 8.2.3R. 
• Clarify the requirements for cross-reference lists under PRM 9.2.16R and PRM 9.4.3R. 
• Updates to cross references and terminology within the PRM to ensure clarity and consistency. 

The instrument came into force on 31 July 2026. 

The Handbook Notice is available here: Handbook Notice 143 

London Stock Exchange – New AIM Rules 

On 5 August 2026, the London Stock Exchange published AIM Notice 64, in which it provided feedback on its June 2026 consultation on AIM Notice 62 and confirms the implementation of changes to the AIM Rules for Companies and the AIM Disciplinary Procedures and Appeals Handbook.  

The Exchange proposes to implement all proposed rule changes with some minor amendments. AIM Notice 64 includes commentary and clarifications on changes made in relation to certain areas, including: 

Streamlining Admissions 

The AIM reforms simplify the admission process by removing the working capital statement requirement, permitting incorporation by reference, allowing the use of UK GAAP, and introducing more flexible lock-in arrangements. Admission documents will focus on key investor information and include a clear reminder that AIM is a "buyer beware" market. 

New Admission Routes and Faster Market Access 

A new Express Market route provides a quicker and more proportionate pathway to AIM for companies already listed on recognised international markets. Documentation requirements are reduced, admission timetables are shortened, and dual-listed companies can rely more heavily on existing disclosures. 

Facilitating Secondary Fundraisings 

The introduction of Capital Access Windows allows companies to temporarily suspend trading while conducting fundraisings, helping to reduce share price volatility and broaden investor participation without compromising existing AIM or MAR obligations. 

Facilitating M&A Activity 

The reforms make acquisitions easier by narrowing the circumstances in which transactions are treated as reverse takeovers, reducing the likelihood of trading suspensions, and aligning transaction thresholds more closely with the UK Listing Rules. 

Greater Flexibility for Growth Companies 

The new rules provide greater freedom over remuneration structures and continue to permit special voting share arrangements, supporting founder-led and high-growth companies while maintaining appropriate investor protections. 

Corporate Governance Reforms 

AIM is moving away from a formal "comply or explain" approach towards disclosure of a company's governance arrangements. The emphasis is on providing investors with clear information about governance practices, remuneration frameworks, and engagement with proxy advisers. 

Strengthening the Role of Nomads 

The reforms reinforce the central role of Nomads by requiring companies to engage with them on material business developments, market disclosures and regulatory obligations. Companies must also maintain appropriate systems and controls to identify developments that could affect investors. 

The revised AIM Rules for Companies and AIM Disciplinary Procedures and Appeals Handbook come into effect immediately. 

The AIM Rules can be accessed here: AIM Rules for Companies - August 2026

London Stock Exchange – New AIM Rules for Nominated Advisers 

On 5 August 2026, the London Stock Exchange published AIM Notice 65, in which it provides feedback on the June 2026 consultation in Aim Notice 63 and confirms the implementation of amendments to the AIM Rules for Nominated Advisers (Nomad Rules).

Feedback from the consultation was overwhelmingly in support of the changes and the Exchange proposes to implement all proposed rule changes with no amendments.

The Exchange notes that:

• It remains the responsibility of an applicant and its directors to assess the company's financial position following admission as part of the company's wider assessment of its capital resources when coming to AIM.
• The Technical Note published alongside AIM Notice 63 reflects AIM Regulation’s policy and guidance on the interpretation of the Nomad Rules and as such are not rules themselves. The Technical Note may be updated from time to time in accordance with market practice.

The revised Nomad Rules come into effect immediately and can be accessed here: AIM Rules for Nominated Advisers - August 2026

FCA – Policy Statement – Changes to Information Flows for UK Equity IPOs 

On 5 August 2026, the FCA published Policy Statement, Changes to information flows for UK equity IPOs (PS26/16). The FCA consulted on the proposed changes in CP26/14.  The Policy Statement provides responses to the feedback it received on CP26/14 and the final FCA instrument.

The changes set out in CP26/14 will be implemented as proposed. The changes are made through amendments to the Conduct of Business sourcebook (COBS) which are set out in the Changes to Information Flows for UK Equity IPOs Instrument 2026 (FCA 2026/53). No changes have been made to the draft instrument included in CP26/14.

The changes include:

• Amendments to COBS 11A.1.4FR (Timing restrictions for disseminating research on equity IPOs) to remove the seven-day waiting period between the publication of an approved prospectus or registration document and connected research (where there is no joint unconnected and connected analyst briefing) and the one-day waiting period (where there is a joint briefing).
• Deletion of COBS 11A.1.4BR to COBS 11A.1.4ER (Communications between the issuer and research analysts in equity IPOs).
• Deletion of COBS 11A.1.4BR to COBS 11A.1.4ER (Communications between the issuer and research analysts in equity IPOs).
• Amendments to COBS 12.2.21R (Measures and arrangements required for investment research) to correct a technical drafting error that arose when the text was transferred from the MiFID Organisational Regulation.

The changes to COBS came into effect on 5 August 2026.

The FCA Policy Statement is available here: PS26/16: Changes to information flows for UK equity IPOs 

Companies House –  Transition Plan Update

On 5 August 2026, Companies House published its updated outline transition plan for reforming its role in connection with ECCTA.

The updated plan confirms that the due date for the implementation of the following requirements has been postponed until no earlier than November 2027:

• Compulsory identity verification for any presenter filing a document at Companies House.
• The requirement for any third-party agent filing on behalf of a company to be registered as an authorised corporate service provider (ACSP).
• Companies House has stated that they will give at least 6 months’ notice before these requirements come into effect.

The updated plan also confirms that the due date for the implementation of the following requirements has been postponed until April 2028 onwards:

• The requirement for small companies and micro entities to file profit and loss accounts with Companies House, but with the option to opt out of publishing this information on the public register.
• The requirement for all companies to file their annual accounts using commercial software.
• The removal of the option for companies to file abridged accounts.
• The requirement for a strengthened eligibility statement for all companies claiming an audit exemption.
• The requirement for component parts of the filed accounts and reports to all be filed together.
• The reduction of the number of times a company can shorten its accounting reference period.

The Outline Transition Plan is available here: Economic Crime and Corporate Transparency Act: outline transition plan for Companies House.

FCA – Introducing an Inside Information Declaration when Submitting Documents to the FCA 

On 7 August 2026, the FCA updated the "Submit a prospectus or circular" page of its website to include a requirement that an inside information declaration form be provided when a document is submitted to the FCA.  

The form is available on the "Forms and checklists" page of the FCA website. It provides confirmation to the FCA of whether or not the transaction or document contains inside information, as defined in Article 7 of the UK Market Abuse Regulation, so that the appropriate controls can be applied in the review process. If inside information is included, an explanation of what that information is must be given. The form is to be signed on behalf of the issuer and/or sponsor.    

All first submissions of equity documents, including guidance requests, must include the form from 21 September 2026.  

The FCA circular is available here: Submit a prospectus or circular and the forms via: Forms and checklists