EQ Monthly Bulletin - September 2026

In This Edition:

• Companies House – Assessment Criteria for Authorised Corporate Service Providers
• Financial Conduct Authority – Primary Market Bulletin 65 – Content of Regulatory Announcements
• QCA Annual Review 2025/26: Key Takeaways
• Financial Reporting Council – Our Approach to Regulation
• Department for Business, Innovation, Science and Trade – Modernising Corporate Reporting Consultation

Companies House – Assessment Criteria for Authorised Corporate Service Providers

On 11 August 2026, Companies House published guidance on the criteria it will apply when assessing whether an applicant, or existing Authorised Corporate Service Provider (ACSP), is fit and proper to carry out ACSP functions. 

The guidance supports the Registrar's duty under section 1098B of the Companies Act 2006 to refuse an application to register an ACSP if the applicant is not fit and proper, and to monitor existing ACSPs to ensure they continue to meet the standard after registration. 

The guidance is non-exhaustive and confirms that the Registrar will assess all relevant circumstances on a case-by-case basis, taking account of the seriousness, timing and resolution of any concern. It identifies four principal areas of assessment:

• Eligibility and competence. Whether the applicant has appropriate anti-money laundering (AML) supervision and is suitable to carry out ACSP functions, including whether connected entities have been dissolved, are being struck off or are subject to insolvency proceedings.
• Criminal, regulatory and financial history. Relevant matters include bankruptcy, director disqualification, criminal convictions, regulatory or disciplinary findings, and serious or repeated failures to meet statutory obligations to Companies House.
• Honesty, integrity and conduct. This includes previous dealings with Companies House, false or misleading filings or statements, and other conduct that raises concerns over reliability, transparency or compliance.
• History with Companies House and ACSP activity. Relevant matters include the way an ACSP carries out verification, reverification and filing activity, and compliance with statutory filing requirements.

The Registrar may also consider aggravating factors (such as repeated patterns of concern or evidence of risk to the integrity of the register) and mitigating factors (such as evidence of good conduct or steps taken to prevent recurrence).

The guidance emphasises that AML supervision is distinct from the Registrar's fit and proper assessment.

If concerns arise after registration, Companies House may ask for information, suspend ACSP status or cease registration. Before ceasing registration, the ACSP will generally have an opportunity to make representations. Providing inaccurate information or failing to respond to Companies House may be taken into account in the fit and proper assessment.

Further information can be viewed here: Fit and proper criteria for Authorised Corporate Service Providers - GOV.UK

Financial Conduct Authority – Primary Market Bulletin 65 – Content of Regulatory Announcements

On 28 August 2026, the FCA published Primary Market Bulletin 65 (PMB 65). Among other things, PMB 65 covers:

• The FCA's concerns about potentially misleading statements in regulatory announcements which, in certain cases, appear to contain or resemble marketing material rather than regulated information. The FCA has observed issuers using language which is vague, exaggerated and flamboyant. The FCA has found this particularly concerning when considered alongside issuers releasing regulatory announcements more often than appears necessary, making announcements which are marked as containing inside information when they do not, and releasing announcements in tandem with a very significant spike in the issuers' share price.
• The FCA's review of sponsors' use of expert reports to support specialist due diligence for new admissions to the Equity Shares (Commercial Companies) (ESCC) category. The FCA reminds sponsors that it expects them to take an active role in determining the nature and extent of expert reporting specific to the transaction.
• The FCA did not identify widespread or systemic failures in the application of the delay mechanism in Article 17(4) of UK MAR.
• The new inside information declaration form for listings submissions via the Electronic Submission System (ESS), which is now available from the FCA's website. The form will apply to all new equity cases, including guidance requests, submitted through the ESS portal from Monday 21 September 2026. The new form must be included with the first submission of documents.

The Primary Market Bulletin is available here: Primary Market Bulletin 65 | FCA

QCA Annual Review 2025/26: Key Takeaways

The QCA's Annual Review was published in September 2026, highlighting developments in governance, AGM practices, capital markets reform and regulatory engagement affecting AIM and growth companies. The Review states QCA Code adoption remains high, with 92% of AIM companies using the Code. More companies are also taking advantage of its flexibility by explaining departures from specific provisions, particularly smaller issuers.

Key highlights include:

• AGM reform remains under discussion, with the QCA calling for legal recognition of virtual AGMs, shareholder consent for changes to AGM formats, and continued flexibility for companies.
• Access to capital remains a priority, including proposals for a £1 billion small-cap investment portfolio through the British Business Bank and support for measures to improve market liquidity and valuations.
• Capital markets reforms progressed during the year, including prospectus reforms, initiatives to increase retail investor participation and the introduction of revised AIM Rules.
• The QCA continued active engagement with policymakers and regulators on issues including sustainability reporting, corporate reporting reform, AIM regulation, taxation and financing growth companies.

Review points to continued focus on governance flexibility, modernising shareholder meetings, regulatory change and improving the funding environment for UK quoted companies.

The full report can be accessed here: 1.6-QCA-AnnualReview-2526.pdf.pdf

Financial Reporting Council – Our Approach to Regulation

The Financial Reporting Council (FRC) published Our Approach to Regulation on 3 September 2026, providing insight into how the regulator applies the principles of the Regulators' Code across its activities. While it introduces no new requirements, it signals the themes likely to shape the FRC's regulatory approach.

• Good governance, reporting and accountability are viewed by the FRC as important contributors to market confidence, investment and economic growth.
• Proportionate regulation remains a core principle, with the FRC seeking to take account of an organisation's size, complexity and risk profile rather than applying a one-size-fits-all approach.
• Risk-based supervision is central to the FRC's activities, with regulatory attention focused on areas presenting the greatest potential harm to investors, markets and stakeholders.
• Stakeholder engagement and transparency continue to be key priorities, supported by consultations, guidance, thematic reviews and direct engagement with market participants.
• The FRC's integrated model of standard-setting, supervision and enforcement means regulatory findings are increasingly used to inform future standards, guidance and expectations.

The FRC expects governance, reporting and control frameworks to be proportionate, risk-focused and capable of demonstrating effective oversight, while maintaining high standards of transparency and accountability.

The report can be accessed here: Our Approach to Regulation

Department for Business, Innovation, Science and Trade – Modernising Corporate Reporting Consultation

On 7 September 2026, the government published its consultation on modernising corporate reporting, proposing a "once-in-a-lifetime" overhaul of UK financial, non-financial and corporate governance reporting frameworks.

Key proposals include:

• Making investors and creditors the primary audience for the annual report and accounts, guided by five principles (clarity of purpose, flexibility and trust, simplicity and coherence, proportionality, and fit for the future).
• Simplifying company categories, thresholds and exemptions, including removing the small/medium-sized company distinction, extending exemptions to more company types, amending the average number of employees condition for determining a company's nature and creating a new, very large company threshold for certain non-financial reporting.
• Reforming financial reporting by removing detailed requirements from the Companies Act 2006, making accounting standards the single source of detail, reducing available standards to four, extending small-company exemptions to medium-sized companies and requiring audit only where risks justify the cost.
• Reforming strategic reporting by refocusing it on investors and creditors, introducing new baseline requirements (business model, performance, resources and relationships, strategy and principal risks) to replace the disclosure lists in sections 414C(7)(b) and 414CB(2)(b) to (d) of the Companies Act 2006, replacing the section 172 statement, and removing the sex-breakdown disclosure under section 414C(8)(c).
• Replacing the rules on distributable profits with a solvency-based regime, under which companies would instead confirm that a dividend or other profit distribution will not affect their ability to continue as a going concern.
• Streamlining corporate governance and remuneration reporting, including potentially removing the advisory vote on the remuneration report and CEO-employee pay reporting.
• Considering specific cyber security reporting for very large companies and exploring how to improve trust in the assurance of sustainability-related reporting.
• Modernising corporate communications, including a digital-first presumption for annual reports, clarifying that the "place" of a meeting under section 311 of the Companies Act 2006 can include virtual locations (with shareholder consent and possible safeguards) and giving the FRC powers over electronic formatting standards.
• Introducing a Reporting Gateway, requiring Companies House notification of auditor changes and revoking the Reports on Payments to Government Regulations 2014.

The consultation closes on 30 November 2026. The government aims to publish a response within six months of that date.

The consultation can be accessed here: Modernising Corporate Reporting to support long-term economic growth