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FRC: a drive towards better reporting

FRC and your reporting

Be more transparent, balanced and company-specific in your reporting, the Financial Reporting Council (FRC) urges businesses in its Annual Review of Corporate Reporting.

Nick Chandler


KPMG in the UK


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The FRC’s annual review, issued every autumn, summarises its corporate financial reporting review work undertaken in the UK over the previous twelve months – including an assessment of the quality they have found. This year, the FRC also issued thematic reviews on pension disclosures, Alternative Performance Measures (APMs), together with disclosure of judgements and estimates.

Of particular interest for preparers is the insight the annual review offers into the FRC’s focus areas for planned reviews of company's accounts, ahead of the forthcoming reporting season.

The FRC is focusing on narrative disclosure and is calling for transparent and balanced reporting – encouraging companies to provide entity-specific rather than generic information in those areas they view as the most critical and judgmental to the longer term success and strategy of the entity.

Given the sheer volume of information included in most annual reports, it is sometimes hard for investors and other stakeholders to pinpoint the key areas of judgement and estimate affecting the numbers in financial statements. That could include, for example, judgements required over the timing of revenue recognition or over the determination of a particular sensitive assumption, when calculating a provision.

Getting the balance right

Investors are looking for a balanced analysis of an entity’s performance. They need to be able to understand the judgements made by directors in choosing appropriate non-GAAP measures when describing the performance of the entity. They are also looking for transparency in describing the risks that might affect the entity: the effect of Brexit on their business model, for example.

Above all, the FRC believes that directors should avoid boilerplate descriptions, in order to make the disclosure entity-specific. That means including only those areas that actually required judgement, rather than a shopping list of all the possible risks an entity might face.

Below is a selection of the points on which the FRC will be focusing in future reviews: for a fuller description, see the FRC’s reports.

Alternative Performance Measures

  • A definition for all APMs, including ratios such as cash conversion, organic revenue growth.
  • “Non-recurring”, “one-off”, “unusual” or “infrequent” should not generally be used to describe items that recur, such as impairment and restructuring costs.
  • Clear explanations of why each APM is used (more than merely “most meaningful”), and explanations of why individual items have been excluded from an adjusted measure.
  • Reconciliations for all APMs.

Strategic Report

Companies will be expected to provide a balanced review, giving equal prominence to those areas of the business performing well and less well – and showing a clear link between the discussion of strategy, KPIs and the financial statements.

Judgements and estimates

  • Distinguish between judgements and estimates
  • Less is more: focus on the estimates that risk materially changing in next year’s accounts.
  • Make disclosure more company specific and granular. In particular, for each estimate:

- Disclose the amount subject to the estimation uncertainty, rather than just the balance sheet line item in which it is included. Tax uncertainties, in particular, were highlighted as an area where insufficient disclosure is often given.

- Quantify assumptions (for example, the forecast price of platinum used to make an estimate).

  • In a shift in focus, the FRC also expects to see the disclosure of material changes to estimates made at previous balance sheet dates. This may highlight whether previous disclosures of material estimates were complete and appropriately describe the possible effect on the following year.

Looking ahead

The FRC will also review 2018 interim accounts to assess disclosures on the effect of adopting IFRS 9 and 15. The focus will be on industries where these standards are expected to have a material effect.

For the next season, the FRC has already announced the focus areas for its thematic reviews. It will contact about 40 companies in the smaller listed and AIM segment, notifying them about which two of the five areas they will be assessing. These areas are: APMs, accounting policies including judgements and estimates, cash flows statements, tax and pensions.

FRC Thematic Review on Alternative Performance Measures

FRC Thematic Review on Estimates and Judgements

FRC Thematic Review on Pensions

FRC Annual Corporate Reporting 2016/17 

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