EQ Monthly Bulletin - June 2026

In This Edition:

1. Department for Science, Innovation and Technology – Voluntary Cyber Resilience Pledge
2. The King’s Speech – Corporate Aspects
3. Register of Overseas Entities (Protection and Trusts) and Limited Liability Partnerships (Application of Company Law) (Amendment) Regulations 2026 – Withdrawal and Republication
4. Financial Services Regulatory Initiative Forum – Regulatory Initiatives Grid
5. Commercial Payments Bill
6. Financial Reporting Council – Digital Reporting
7. Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations – Post-implementation Review
8. London Stock Exchange – AIM Notice 62
9. London Stock Exchange – AIM Notice 63
10. Ministerial Statement – Companies House Accounts Reforms in relation to the Economic Crime and Corporate Transparency Act (ECCTA)
11. Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (Regulations)

Department for Science, Innovation and Technology – Voluntary Cyber Resilience Pledge

On 22 April 2026, the Department for Science, Innovation and Technology announced their invitation for UK companies to make a voluntary Cyber Resilience Pledge. This has been developed following the positive response to the ministerial letter sent to CEO’s and Chairs of leading UK companies in autumn 2025, inviting them to take three specific actions to protect cyber resilience:

1. Make cyber a board responsibility
2. Sign up to early warning
3. Register to the Cyber Essentials Supplier Check Toolkit within two months of signing the pledge

In addition, companies signing the pledge would commit to:

• Encourage these actions within their own supply chains
• Publish the signed pledge declaration on the company’s website

Further details on the Cyber Resilience Pledge can be accessed here: Cyber Resilience Pledge declaration - GOV.UK

The King’s Speech – Corporate Aspects

On 13 May 2026, the King's Speech was delivered, setting out the government's proposed programme of legislation for the next Parliamentary session.

Corporate aspects include:

• Small Business Protections (Late Payments) Bill - will require boards or audit committees of persistently late-paying large companies to publish commentary on poor payment performance and intended actions to address it.
• Competition Reform Bill - will give more certainty about whether a merger is likely to be reviewed in the UK by clarifying the tests the Competition and Markets Authority (CMA) use to assess whether it has jurisdiction to investigate a merger.

The King’s Speech can be accessed here: The King's Speech 2026 - GOV.UK

Detailed briefing notes are available here: The King's Speech 2026 -  Briefing Notes.pdf

Register of Overseas Entities (Protection and Trusts) and Limited Liability Partnerships (Application of Company Law) (Amendment) Regulations 2026 – Withdrawal and Republication

On 13 May 2026, the House of Commons Votes and Proceedings and the House of Lords Business and Minutes of Proceedings have each noted that the draft Register of Overseas Entities (Protection and Trusts) and Limited Liability Partnerships (Application of Company Law) (Amendment) Regulations 2026 were withdrawn in favour of a revised draft to be laid before parliament on 2 June 2026.

The revised draft Regulations are materially the same as those laid before parliament on 22 April 2026, but the amendment made to regulation 2 (interpretation) of the Register of Overseas Entities (Delivery, Protection and Trust Services) Regulations 2022 has now been removed. As a result, the definition of "relevant individual" contained in the Register of Overseas Entities (Delivery, Protection and Trust Services) Regulations 2022 remains unchanged

The draft became law on 9 June 2026.

The Draft Statutory Instrument and Explanatory Memorandum can be accessed here: Draft statutory instrument and explanatory memorandum

Financial Services Regulatory Initiative Forum – Regulatory Initiatives Grid

On 19 May 2026, the Financial Services Regulatory Initiatives Forum published the Regulatory Initiatives Grid for May 2026, setting out the expected timeframes for regulatory initiatives, including those by the Financial Conduct Authority (FCA) and the Dematerialisation Market Action Taskforce.

These include:

• Disclosure and Transparency Rules (DTR) - the FCA will start a review of the value of the current DTR and whether changes are needed. A public document will be published by the FCA in Q3 2026.
• Dematerialisation - the Dematerialisation Market Action Taskforce (DEMAT) will report by summer 2026 with a recommended go-live date for step one of its three-step process, the go-live date should be before the end of 2027.
• UK Listing Rules (UKLR) and investment entities - the FCA plans to consult on aspects of the UKLR to consider the eligibility criteria for the listing of specific types of investment entities and will also conduct targeted work to assess how rules, in the context of company law, ensure that boards support strong shareholder rights and engagement, and manage conflicts of interests. A consultation paper is expected with the intention of completing the work by the end of Q4 2026. For a more in depth look at the background to the FCA’s consultation, see our article FCA Review Of Listing Rules For Investment Trusts
• Sustainable finance - the FCA plans to publish a policy statement on its consultation relating to UK Sustainability Reporting Standards (CP26/5) in Q4 2026.

The Regulatory Initiatives Grid (May 2026) is available to view here: Regulatory Initiatives Grid: May 2026

Commercial Payments Bill

On 19 May 2026, the Commercial Payments Bill was introduced to the House of Lords for its first reading. The Bill implements a range of measures to tackle late payments with the announcement of the Bill following the King's Speech on 13 May 2026 (see previous item above). The Bill’s second reading took place on 9 June 2026 in the House of Lords and a Committee stage for line-by-line examination of the bill, is yet to be scheduled.

The Bill amends and enhances existing laws on late payments by introducing the following key measures:

• Statutory maximum payment terms of 60 days (with exceptions)
• Mandatory interest on late payments at 8% above the Bank of England base rate
• A window for raising invoice disputes, after which suppliers will be entitled to a fixed sum if purchasers raise invoice disputes
• Additional investigatory and adjudication powers for the Small Business Commissioner and a power to take enforcement action against larger businesses that persistently engage in poor practices (including issuing fines up to a maximum of 1% of annual turnover in the UK)
• A ban on deducting and withholding retention payments under construction contracts

The Bill aims to help small businesses, self-employed and sole traders, while the new ban on deducting and withholding retention payments under construction contracts is a significant change.

More detail will follow in secondary legislation.

Further information on the Bill can be viewed here: Commercial Payments Bill: overview - GOV.UK

Financial Reporting Council – Digital Reporting

On 20 May 2026, the Financial Reporting Council (FRC) published its 2025/26 annual report on structured digital reporting, using market-wide analysis of digital reports from FCA-listed companies, as well as detailed reviews of 30 annual reports.

The report highlights the following issues regarding digital reporting:

• Companies are often applying only a single, high-level tag to disclosures covering multiple accounting topics
• Companies are creating custom tags (called extensions), as allowed by the IFRS taxonomy, where such extensions are not necessary
• When companies create extensions, they are often too broad or imprecise
• Companies sometimes apply tags based on label wording instead of the underlying accounting meaning
• Companies often make errors reporting their earnings per share, usually as a result of incorrect scaling (i.e. £75 instead of 75 pence).

The report also notes issues relating to process and compliance, such as:

• failure to make the reports easily available on the respective company's website or in a viewer-friendly format
• validation errors and warnings not being fully investigated or resolved before filing
• companies filing their structured reports late or failing to ensure successful publication on the National Storage Mechanism (NSM)
• mandatory UK-specific tags being omitted or applied incorrectly

The report can be accessed here: Structured Digital Reporting: Insights 2025/26

Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations – Post-implementation Review

On 26 May 2026, a post-implementation review of the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 was published, assessing the Streamlined Energy and Carbon Reporting (SECR) framework.

The recommendation of the review is to retain the SECR requirements but with amendments. The review found opportunities to improve the effectiveness, and reduce the administrative reporting burden, of the SECR including:

• Most in-scope entities comply with SECR but compliance is not universal
• Reporting under SECR is generally manageable and proportionate, though uneven across organisations
• Stakeholders emphasised the need for better alignment with ISSB and CSRD to reduce duplication and maintain SECR's relevance
• 79% of businesses disclosed data they otherwise would not have published
• Updating the Environmental Reporting Guidelines to provide clearer definitions and practical examples
• Introducing a standardised SECR disclosure template
• Aligning SECR requirements, definitions and metrics with international standards and domestic frameworks (such as ISSB, CSRD and TCFD) to remove duplication and improve coherence.
• Introducing light-touch forward-looking elements, such as optional targets or qualitative narratives, to maintain engagement
• A possible exploration of digital solutions (i.e. centralised/digital filing)

It is intended that the above potential areas for improvement will be explored through a 2026 consultation on streamlining energy and emissions reporting.

The Post Implementation Review can be accessed here: 2026 post-implementation review of the SECR regulations 2018

London Stock Exchange – AIM Notice 62

On 4 June 2026, the London Stock Exchange published AIM Notice 62, in which it consults on proposed changes to the AIM Rules and the AIM Disciplinary Procedures and Appeals Handbook. The consultation follows its November 2025 Feedback Statement on Shaping the Future of AIM.

The consultation covers the following key topics:

• Reducing unnecessary admission burdens
• Easier fundraisings and enabling retail participation
• Supporting AIM company acquisition activity
• Greater flexibility for innovative and growing companies
• Greater agency for AIM companies
• Attracting international companies
• Leveraging nominated adviser expertise
• Buyer beware
  In addition the LSE are proposing additional amendments and administrative changes covering measures to maintain standards of compliance and conduct, retiring the Inside AIM guidance, extending the period to appoint a replacement nominated adviser, changes to the notifications requirements for share buybacks, disclosure of directorships, and removal of the six-monthly return in relation to block admissions.

The consultation closes on 2 July 2026. A further consultation on the contents of an admission document is expected in due course.

AIM Notice 62 can be accessed here: AIM Notice 62 - Consultation on changes to the AIM Rules for Companies.pdf

London Stock Exchange – AIM Notice 63

On 4 June 2026, the London Stock Exchange published AIM Notice 63, in which it consults on draft amendments to the AIM Rules for Nominated Advisers (Nomad Rules). The Exchange has also published a new Nominated Adviser Technical Note (Technical Note), which sets out the expectations of nominated advisers in performing their obligations under the Nomad Rules.

The consultation closes on 2 July 2026.

The Technical Note incorporates relevant guidance from Inside AIM, which the Exchange will retire on implementation of the new AIM Rules. It sets out expectations of nominated advisers regarding performance of their obligations under the Nomad Rules in the following areas:

• The role of the nominated adviser
• The role of the company
• Education of directors on AIM Rules responsibilities
• Due diligence on take-on of an AIM company
• Nominated adviser work on admission, including on-site visits, appointing lawyers and reporting accountants, free float considerations and early notifications
• Ongoing work on AIM Rules guidance
• The admissions self-service portal

The Exchange is not consulting on the Technical Note but will engage with the nominated adviser community and update the note from time to time, as appropriate, to ensure its effectiveness.

AIM Notice 63 can be accessed here: AIM Notice 63 - Consultation on changes to the AIM Rules for Nominated Advisers.pdf

Ministerial Statement – Companies House Accounts Reforms in relation to the Economic Crime and Corporate Transparency Act (ECCTA)

On 9 June 2026, the government made an announcement concerning the implementation of measures introduced by ECCTA to reform how companies report information and what information they report when filing their annual accounts with Companies House.

Following engagement with stakeholders, the government has decided to proceed with the reform, with the following changes:

• The reforms will come into effect from April 2028 (originally scheduled for April 2027)
• The requirement for small companies and micro-entities to file profit and loss accounts with Companies House will be implemented but, in response to concerns about commercial risk and the potential impact on investment opportunities, small companies and micro-entities will be able to choose to opt out of publishing this information on the public register (Companies House, law enforcement and HMRC will still have access to the information). Details of how to opt out will be confirmed in due course

Other accounts reforms include:

• The requirement for all companies to file their annual accounts via commercial software (the CGI published a technical briefing update regarding the filing of annual accounts which can be viewed here: Technical Update: June 2026 - Update)
• The removal of the option for companies to file abridged accounts
• The requirement for a strengthened eligibility statement requirement for all companies claiming an audit exemption
• The requirement for component parts of the accounts and reports to be filed together

Secondary legislation will be brought forward to reduce the number of times a company can shorten its accounting reference period and to introduce annotations to the register where a company has not complied with a notice regarding companies of its accounts with the Companies Act 2006 requirements. From April 2028, companies will need to give a business reason for shortening their accounting reference period more than once in five years.

The Ministerial Statement announcing the update can be accessed via this link: Written statements - Written questions, answers and statements - UK Parliament

Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (Regulations)

On 9 June 2026, the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (Regulations) were made and published, together with an explanatory note. The regulations amend the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) and related provisions in the Terrorism Act 2000 and the Proceeds of Crime Act 2002.

The regulations make several changes, in particular:

• Amendments to the customer due diligence (CDD), enhanced due diligence (EDD) and additional customer due diligence requirements relating to cryptoasset businesses, unusually complex or unusually large transactions, the Financial Action Task Force (FATF) call for action countries and pooled accounts
• Strengthening the anti-money laundering (AML) regime for cryptoasset businesses, including new EDD for cryptoasset correspondent relationships and amendments to the change in control regime for registered cryptoasset businesses, following the financial services regulatory framework for cryptoassets established under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026
• New provisions for insolvent bank customers, permitting credit institutions, in limited circumstances, to establish a business relationship, open accounts and allow transactions to take place before completion of full CDD, and modifying the timing of verification and registerdiscrepancy reporting requirements in such cases
• Changes to the Trust Registration Service (TRS), including extending registration and datasharing requirements to certain nonUK trusts that acquired UK land before 6 October 2020 and continue to hold it, introducing a de minimis exemption for certain lowvalue nontaxable trusts, and removing Stamp Duty Reserve Tax as a standalone trigger for registration
• Updating the definition of "highrisk third country" by reference to FATF call for action countries

The regulations will mostly come into force on 30 June 2026. The new enhanced due diligence requirements for cryptoasset correspondent relationships come into force on 1 February 2027.

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