We’ll focus on what really matters, from emerging trends to upcoming requirements, with a few practical reminders and helpful tips along the way.
Proxy Advisors Tighten Expectations on Executive Pay Reporting
Proxy advisers are sharpening their focus on how companies report executive remuneration, as updated guidance from Glass Lewis and ISS puts renewed pressure on boards to demonstrate transparency and stronger alignment between pay and performance. The firms’ latest recommendations also underscore the growing expectation that ESG measures will be meaningfully integrated into incentive structures.
Against this backdrop, companies are being encouraged to clearly articulate how their remuneration framework links to strategy, how performance is assessed, and the extent to which shareholder feedback has influenced pay outcomes.
Remuneration committees and company secretaries are increasingly advised to monitor proxy adviser bulletins ahead of investor engagement, particularly as AGM voting season approaches, when scrutiny over pay practices typically intensifies.
Please do take a look at the ISS and Glass Lewis Policy Update published by our EQ Proxy colleagues in December for further information.
EQ Proxy: ISS And Glass Lewis Policy Updates For 2026 - Equiniti
Board Performance Reviews
Board performance reviews remain a central tool for demonstrating governance effectiveness, with many companies maintaining the established rhythm of a three year external evaluation supplemented by internal assessments in the intervening years. As expectations rise, boards are being urged to place greater emphasis on:
- Culture and behavioural dynamics
- Succession planning and board refreshment
- Decision-making processes
- Diversity of skills and experience
For Company secretaries, the challenge is ensuring that review findings translate into meaningful action. That means producing clear, accountable action plans with defined timelines and reporting transparently on progress in the annual Report and accounts.
See our article below for a more detailed look at board performance reviews and some key considerations.
Employment Rights Act Set to Introduce Mandatory Equality Action Plans
The Employment Rights Bill received Royal Assent on 18 December 2025, formally becoming the Employment Rights Act 2025. Section 78A has been inserted into the Equality Act 2010. This provision paves the way for future regulations requiring employers with 250 or more employees to produce and publish equality action plans.
Under the new section, forthcoming regulations may set out detailed requirements covering the content, format and publication process of these plans, including expectations around senior level approval and the type of workforce information to be disclosed. Once published, companies will not be required to update the plan more often than every 12 months, and the regulations will also specify how compliance will be monitored and enforced.
The government intends to bring these provisions into force in 2027, subject to parliamentary process. As the direction of travel becomes increasingly clear, boards should expect workforce, culture and equality considerations to play a more prominent role in governance and risk discussions. Early collaboration between legal, HR and governance teams will be essential to assess the impact and to shape the development of effective action plans.
Updated QCA Committee Guidance & Terms of Reference
The QCA has released a new Nomination Committee Guide alongside updated guidance for audit and remuneration committees. With the 12-month transition period for applying the QCA Code 2023 now complete, governance teams have a clear runway to modernise committee terms of reference and align documentation with current market expectations.
Block Listing Regime update
The Financial Conduct Authority (“FCA”) is reforming the listing and prospectus regime to reduce administrative burden for listed companies and to support capital raising and market efficiency by cutting redundant approval steps. Following the introduction of the UK’s new Public Offers and Admissions to Trading Regulations 2024 (“POATRs”) - which replaced the UK Prospectus Regulation on 19 January 2026 - the London Stock Exchange (“LSE”) has published updates to its Admission and Disclosure Standards. A key related changed to the UK Listing Rules is the removal of UKLR 20.6.
From 19 January 2026, issuers with an existing listed class of securities no longer need to apply for admission to listing for further issues of that class. Subsequent issuances of already-listed securities are now treated as automatically listed.
However, issuers must still apply to the LSE for admission to trading on the relevant market and continue engaging with exchanges as usual. Although the requirement under UKLR 20.6 for issuers to submit to the market a six-monthly block listing return (“Return”) has been deleted, if any issuer has in the 6 months prior to 19 January 2026 issued shares under an existing block listing, then they are still required to submit a final Return via a Regulatory Information Service.
Regardless of the size of your company or the method it uses to issue shares, it is prudent for governance teams to establish a clear, step by step process to ensure all actions are completed correctly and on time. Early coordination with registrars and brokers will remain essential, particularly during periods of high issuance activity.
Here are a few more reminders
Annual Reports – keep length in check.
Disclosure expectations may be rising, but clarity still matters. Concise narrative drafting, careful use of cross-referencing and layering digital reporting can all help make annual reports easier to navigate without inflating page count. For more practical tips see: How To Produce A Successful Annual Report - EquinitiPlease see our discussion on this at the 2025 EQ Conference.
Preparing for your AGM
Planning for the AGM should start early, covering venue arrangements, hybrid/virtual meeting technology, Q&A protocols, director briefings and shareholder engagement, particularly for resolutions likely to attract scrutiny. Below are some valuable resources for your AGM/shareholder needsAGM Management & Advisory Services for UK Companies | Equiniti
Proxy Solicitation & Corporate Governance Services | EquinitiProvision 29, UK Corporate Governance Code is now effective
Provision 29, relating to internal controls, applies to financial years beginning on or after 1 January 2026. Boards will need robust evidence to support their statements on the effectiveness of internal controls, supported by an assurance framework overseen by the audit committee.Directors and Persons with Significant Control (PSCs) ID Verification (IDV)
Under the Economic Crime and Corporate Transparency Act 2023, directors and persons with significant control will be required to complete identity verification before their next confirmation statement is due. Early preparation will help companies avoid delays that could result in late filings.
Please get in touch if you’d like to discuss how Company Secretarial Services can support with annual report drafting, best practice reviews, and planning for an AGM.