EQ Monthly Bulletin – October 2026

In This Edition:

• WTW and Cevian Capital – Investing in the Boardroom Report
• London Stock Exchange – Dividend Procedure Timetable 2027
• Companies House – Identity Verification Compliance Campaign
• Companies House and Insolvency Service – First Director Identity Verification Prosecutions
• European Commission and EFRAG – Simplified European Sustainability Reporting Standards and Voluntary Sustainability Reporting Standard
• Companies House and Insolvency Service – Seven Companies Wound Up Following Joint Investigation
• Financial Reporting Council – Annual Review of Corporate Reporting 2025/26
• Financial Conduct Authority – Primary Market Bulletin 66
• Financial Conduct Authority – Aligning Listed Issuers’ Sustainability Disclosures with International Standards (PS26/19)
• Investment Association and IVIS – Updated Guidance on Virtual AGMs
• HM Treasury – Financial Services and Markets Act 2023 (Addition of Relevant Enactments) Regulations 2026 
  
  

WTW and Cevian Capital – Investing in the Boardroom Report 

At a Glance: A report published jointly by Willis Towers Watson and Cevian Capital examining non-executive director share ownership, director remuneration structures and board effectiveness, based on analysis of listed company practices and stakeholder views. 

Details: 

On 13 August the report Investing in the Boardroom was published jointly by WTW (Willis Towers Watson) and activist investor Cevian Capital, examining whether stronger alignment between non-executive director remuneration, share ownership and shareholder interests could improve board effectiveness and long-term performance across UK listed companies. 

The report proposes that the effectiveness of UK listed company boards is increasingly constrained by three interconnected issues:  

• relatively low non-executive director (NED) remuneration  
• limited alignment between NEDs and shareholders through share ownership  
• expanding board workloads that reduce the time available for long-term value creation 

The report proposes an Enhanced Board Approach for FTSE 100 companies from the 2027 AGM season, under which existing cash fees would be maintained while an equivalent value of annual share awards would be granted to NEDs.  

The report highlights recent FRC and Investment Association guidance confirming that a proportion of NED fees may be paid in shares without compromising director independence, provided arrangements are not performance related.  

While the proposals are not regulatory requirements, they may influence future shareholder engagement, remuneration policy consultations and the wider debate on board effectiveness, overboarding and governance practices.  

The full report is available to download here: Investing in the boardroom: Pay, alignment and UK plc performance - WTW UK

London Stock Exchange – Dividend Procedure Timetable 2027 

At a Glance: The London Stock Exchange's annual timetable setting out key dates and procedural requirements for dividend payments in 2027, including changes associated with the UK's transition to a T+1 settlement cycle.

Details: 

On 4 September 2026, the London Stock Exchange published its dividend procedure timetable for 2027.  This introduces operational changes arising from the UK's move to a T+1 settlement cycle on 11 October 2027. From that date, the ex-dividend date and record date will occur on the same business day, replacing the current practice where the ex-dividend date typically falls one business day before the record date.

The timetable also highlights a transition period between 4 October and 18 October 2027 during which securities will not be marked ex-dividend. The Exchange advises issuers not to set ex-dividend dates within this window, although dividend announcements and payment dates are unaffected. As a result, issuers should review their 2027 dividend timetables early to ensure ex-dividend dates are scheduled appropriately.

In addition, companies should note that dividend announcements must continue to meet the Exchange's procedural requirements, including publication via a Primary Information Provider (PIP) and inclusion of key information such as the dividend amount, record date, payment date and details of any dividend options. Timetables that fall outside the published guidelines may require prior discussion and agreement with the Exchange's Corporate Actions Team.

The timetable can be accessed here: Dividend Procedure Timetable 2027

For further information, see our EQ article - Accelerated Settlement To T+1 Implementation Impacts Dividend Processes For 2027 And Beyond - Equiniti

Companies House – Identity Verification Compliance Campaign 

At a Glance: A Companies House compliance initiative aimed at directors and people with significant control (PSCs) who are required to complete identity verification under the new Companies House regime. 

Details: 

Companies House has asked the Chartered Governance Institute to draw to the attention of its members a compliance campaign that has recently begun.  

From 26 August 2026, Companies House has been contacting the registered email address of companies where one or more directors or people with significant control (PSCs) have not yet completed their identity verification requirements.  

A key issue identified is PSC compliance. Although an individual only needs to verify their identity once, where the same person is both a director and a PSC, their personal code must be submitted separately for each role. This additional step can be overlooked, resulting in incomplete compliance records. 

If a director or PSC is no longer associated with the company, the company should ensure its register information is updated with Companies House as soon as possible. 

In a sign of increased enforcement activity by Companies House, official figures published in August 2026 showed that 23 directors were disqualified for a combined 70 years following convictions for persistent or serious filing breaches. The directors were also fined a total of £17,810 for failures relating to annual accounts and confirmation statement filings. 

For information on identity verification requirements, including how to provide personal codes, visit: 

•    GOV.UK guidance on identity verification 
•    Providing identity verification details for a PSC 
•    Filing a confirmation statement 

Companies House and Insolvency Service – First Director Identity Verification Prosecutions 

At a Glance: A joint announcement confirming the first prosecutions relating to failures to comply with director identity verification requirements introduced under the Economic Crime and Corporate Transparency Act reforms. 

Details: 

The Insolvency Service and Companies House published a joint press release on 17 September 2026, announcing the first successful prosecutions for breaches of the new director identity verification requirements introduced under the Economic Crime and Corporate Transparency Act 2023.  

Three directors were convicted after failing to comply with the mandatory identity verification regime and were fined by the City of London Magistrates' Court for two related types of non-compliance under the new identity verification regime: 

• One director was convicted for acting as a director without completing the mandatory Companies House identity verification process, including participating in board-level decisions and signing company accounts while unverified. The director was fined £166, with £85 costs and a £66 victim surcharge.
• A second director had verified their own identity but was convicted for failing to take reasonable steps to prevent an unverified individual from continuing to act as a director. As a director of the company, they had a legal responsibility to ensure the company did not permit an unverified person to continue acting as a director. They were fined £307, with £85 costs and a £123 victim surcharge.
• A third director was convicted for continuing to act as a director without completing the mandatory identity verification process, including signing and delivering company accounts while unverified. They were fined £80, with £85 costs and a £32 victim surcharge.  

In addition, all three directors were convicted for their company’s failure to file a confirmation statement within the statutory period.  

The full press release is available here: Directors warned to verify identities with Companies House following first Insolvency Service prosecutions - GOV.UK 

European Commission and EFRAG – Simplified European Sustainability Reporting Standards and Voluntary Sustainability Reporting Standard 

At a Glance: New delegated acts introducing simplified European Sustainability Reporting Standards (ESRS) and a voluntary sustainability reporting standard for eligible undertakings as part of the European Commission's reporting simplification programme. 

Details: 

On 21 September 2026, two delegated Acts, ESRS Simplification Regulation and Voluntary Standards Regulation, relating to European standards for sustainability reporting under the Accounting Directive (2013/34/EU) were published in the Official Journal of the European Union. 

These new EU regulations have simplified the European Sustainability Reporting Standards (ESRS) and introduced voluntary sustainability reporting standards for smaller companies in the value chains of CSRD-reporting entities.  

The UK companies most likely to be affected are UK subsidiaries of EU groups, UK companies with EU-listed securities, large UK groups with substantial EU activities, and UK businesses that sit within the supply chains of CSRD-reporting companies.  

Implementation timetable: 

• 24 September 2026: Commission Delegated Regulation (EU) 2026/1560 (the Voluntary Standards Regulation) enters into force. From this date, eligible undertakings protected by the value chain cap may use the voluntary sustainability reporting standard on a voluntary basis.
• November 2026: EFRAG is expected to publish an updated digital template supporting the voluntary standard.
• 10 November 2026: Commission Delegated Regulation (EU) 2026/1563 (the ESRS Simplification Regulation) enters into force.
• Financial years beginning on or after 1 January 2027: The simplified European Sustainability Reporting Standards (ESRS) apply to entities reporting under the Corporate Sustainability Reporting Directive (CSRD).
• Financial years beginning on or after 1 January 2027: The voluntary standard becomes the framework that CSRD-reporting entities should use when seeking value-chain sustainability information from protected undertakings
• Financial year 2026: Entities already subject to CSRD reporting requirements from 2026 may choose to apply the simplified ESRS requirements early. 

The new voluntary standard could be particularly useful for UK private companies and SMEs that are repeatedly asked for environmental, social and governance (ESG) information by larger EU customers. 

Further information is available here: European Commission adopts revised ESRS and Voluntary Sustainability Reporting Standard: EFRAG welcomes adoption and publishes updated guidance for the Voluntary Standard | EFRAG 

Companies House and Insolvency Service – Seven Companies Wound Up Following Joint Investigation  

At a Glance: A joint investigation by Companies House and the Insolvency Service resulted in the winding up of seven companies following concerns about inaccurate filings and company information. The action highlights increasing scrutiny of the integrity and accuracy of the UK company register. 

Details: 

On 24 September the Insolvency Service and Companies House issued a press release confirming they have secured the winding up of seven companies in the public interest after a joint investigation. 

Investigators identified concerns including filings that appeared to contain false or misleading auditor information, audit firms denying involvement in audits attributed to them, a lack of genuine presence at some registered office addresses, an inability to verify legitimate trading activity, uncertainty over who controlled certain companies, and failures to co-operate with the investigation. The companies were linked through similarities in their incorporation histories, company name changes and business descriptions.  

This case highlights the increasing use of Companies House intelligence and enforcement powers to test the accuracy of information on the public register. The action also demonstrates the growing collaboration between Companies House and the Insolvency Service to identify and act against companies that submit misleading information or fail to comply with statutory obligations. 

The press release is available here: Seven linked companies shut down after Insolvency Service investigation with Companies House - GOV.UK 

Financial Reporting Council – Annual Review of Corporate Reporting 2025/26 

At a Glance: The FRC's annual assessment of the quality of corporate reporting by UK companies, summarising key findings from its monitoring activities and identifying matters arising from company reports and accounts reviewed during the year. 

Details: 

The Financial Reporting Council (FRC)'s Annual Review of Corporate Reporting 2025/26, published on 29 September 2026, reports that the quality of reporting by FTSE 350 companies has been maintained, while reporting quality among other listed and private companies has improved, narrowing the gap between the two groups.  The most common areas of challenge remained cash flow statements, financial instruments, impairment of assets, fair value measurement and revenue recognition. 

The FRC also emphasises preparation for forthcoming reporting changes, including IFRS 18, revised FRS 102 requirements, and reporting against Provision 29 of the UK Corporate Governance Code on material internal controls. The report further reminds boards that responsibility for annual reports remains with directors, including where artificial intelligence is used in the reporting process.  

Key findings: 

• Corporate reporting quality remains strong among FTSE 350 companies and is improving outside the FTSE 350.  
• Cash flow statement errors remain the most common cause of FRC challenge and financial statement restatements.  
• Increased focus is expected on IFRS 18 implementation and internal controls reporting under the UK Corporate Governance Code.  
• Sustainability reporting challenges have reduced, although climate-related disclosures continue to receive regulatory attention.  
• Boards should maintain effective oversight where AI is used in the preparation of corporate reports.  

The report is available here: Annual Review of Corporate Reporting 2025/26

Financial Conduct Authority – Primary Market Bulletin 66 

At a Glance: Primary Market Bulletin 66 provides FCA guidance and consultation updates on sustainability disclosures, working capital statements, cyber incident reporting and UK Listing Rules processes.  

Details: 

On 30 September 2026, the FCA published Primary Market Bulletin 66 (PMB 66), announcing updates to its Knowledge Base, providing guidance on sustainability disclosures, working capital statements, cyber incident disclosures and UK Listing Rules processes.  

Key points: 

• Working capital statements: FCA Technical Note 619.3 has been finalised, updating guidance on basis of preparation disclosures, financing assumptions and the use of uncommitted facilities in working capital assessments. 
• Sustainability reporting: Draft Technical Note 803.1 has been issued for consultation, setting out FCA expectations for the UK SRS "comply or explain" disclosure requirements applying to accounting periods beginning on or after 1 January 2027. It will replace existing sustainability and TCFD-related technical guidance. 
• Cyber incidents: The FCA provides observations on issuers' obligations under the UK MAR inside information regime, including initial assessments, delayed disclosure and subsequent announcements. 
• Chinese auditing standards: The FCA expects issuers using Chinese Standards on Auditing to provide appropriate risk disclosures in prospectuses and admission documents. 
• UKLR checklists: Updated FCA guidance confirms that checklists are only required where FCA approval is needed. 

The Primary Market Bulletin is available here: Primary Market Bulletin 66 | FCA 

Financial Conduct Authority – Aligning Listed Issuers’ Sustainability Disclosures with International Standards (PS26/19) 

At a Glance: An FCA policy statement introducing final rules to align sustainability reporting requirements for listed issuers with the UK Sustainability Reporting Standards (UK SRS). 

Details: 

On 30 September 2026, the FCA published PS26/19: Aligning listed issuers' sustainability disclosures with international standards, confirming the final rules requiring in-scope listed issuers to report sustainability and climate-related information against the UK Sustainability Reporting Standards (UK SRS). The new regime replaces the existing TCFD-aligned climate disclosure requirements and applies to issuers under UKLR 6, 14, 15, 16 and 22.  

Key developments: 

• A single comply or explain approach will apply across all UK SRS disclosure requirements, including climate disclosures (UK SRS S2), non-climate disclosures (UK SRS S1) and Scope 3 emissions disclosures. 
• International commercial companies with a secondary listing (UKLR 14) and depositary receipt issuers (UKLR 15) will also be required to report against UK SRS on a comply or explain basis. 
• The UK Listing Rules (Sustainability Reporting Standards Disclosure) Instrument 2026 (FCA 2026/56) comes into force on 1 January 2027. 
• The requirements apply to accounting periods beginning on or after 1 January 2027, with first reporting expected in 2028. 
• Transitional relief permits a one-year deferral of Scope 3 emissions disclosures and a two-year deferral of UK SRS S1 disclosures.  

The Policy Statement is available here: PS26/19: Aligning listed issuers’ sustainability disclosures with international standards  

Investment Association and IVIS – Updated Guidance on Virtual AGMs 

At a Glance: Updated guidance setting out the Investment Association's and Institutional Voting Information Service's expectations regarding shareholder participation and governance arrangements for virtual and hybrid annual general meetings. 

Details: 

On 6 October 2026, the Investment Association (IA) published updated guidance setting out the safeguards expected by IA members where a listed company conducts a general meeting, including an AGM, with a virtual element. The guidance applies to AGMs of companies with financial year ends on or after 30 September 2026. 

Key provisions: 

• The IA states a preference for hybrid meetings, comprising a physical meeting location supported by electronic participation, rather than virtual-only meetings. 
• Where a virtual element is used, shareholders should be able to see and hear directors and other shareholders, participate in real time and ask questions during the meeting. 
• All board members should participate in the meeting and be clearly visible throughout proceedings. 
• Companies should ensure suitable technology and contingency arrangements are in place to support shareholder participation. 
• Companies should provide transparency on how shareholder questions are managed, including where questions are grouped or filtered, and publish a record of all questions submitted, including unanswered questions, after the meeting. 
• Meeting notices should explain the safeguards that will apply to the virtual element before the meeting takes place. 
• Companies seeking shareholder approval to amend articles to permit virtual-only meetings should explain whether the amendment is intended to provide flexibility or will be used at the next AGM. 
• IA members expect companies using a virtual meeting element to seek shareholder reapproval by advisory ordinary resolution every three years from first use. 
• The Institutional Voting Information Service (IVIS) states it will not raise concerns where meeting notices confirm these expectations have been met but may issue a red-top recommendation where companies seek article amendments without providing the expected assurances or fail to seek reapproval within the expected timeframe. 

The Updated Guidance is available here: IA Position - Virtual AGMs- Final.pdf 

Explore the debate on the future of the AGM by reading our article, The Future of the AGM: Where Is The UK Market Heading?

HM Treasury – Financial Services and Markets Act 2023 (Addition of Relevant Enactments) Regulations 2026 

At a Glance: Draft regulations proposing additional legislation that may be modified within Financial Market Infrastructure sandboxes established under the Financial Services and Markets Act 2023. 

Detail: 

On 12 October 2026, the draft Financial Services and Markets Act 2023 (Addition of Relevant Enactments) Regulations 2026 was published. The Regulations expand the legislation that may be modified through the Financial Market Infrastructure (FMI) sandbox framework established under sections 13 to 17 of the Financial Services and Markets Act 2023. 

Key developments: 

• The Regulations add legislation including the Financial Services (Banking Reform) Act 2013, the Payment Services Regulations 2017 and the Companies Act 1989 to the scope of the FMI sandbox powers. 
• This enables HM Treasury, when establishing or amending an FMI sandbox, to apply, disapply or modify the effect of specified legislation through secondary legislation made under the FSMA 2023 sandbox framework. 
• The changes support the use of developing technologies, including distributed ledger technology (DLT), in regulated financial market infrastructure activities such as securities settlement systems and trading venues. 
• The Digital Securities Sandbox (DSS) is the first FMI sandbox established under these powers and is supervised by the Bank of England and the Financial Conduct Authority. 
• HM Treasury did not undertake a formal consultation on the Regulations but engaged with the Bank of England and FCA during their development. 

The Regulations will come into effect on the day after they are made, they are yet to be considered by the Joint Committee on Statutory Instruments. 

The Regulations themselves do not change any substantive legal requirements, any legislative changes would be introduced separately through secondary legislation 

The Legislation is available here: The Financial Services and Markets Act 2023 (Addition of Relevant Enactments) Regulations 2026 

The Explanatory Memorandum is available here: The Financial Services and Markets Act 2023 (Addition of Relevant Enactments) Regulations 2026