Post # 95
December 19, 2025
Claire Bodanis
Claire offers a handmade Christmas present to all reporters, and the Department for Business and Trade’s corporate reporting review team. Says Claire: ‘Enormous thanks to the 50+ FTSE companies, technical and regulatory experts, auditors and investors, whose contributions greatly improved my own handiwork.’
One of my favourite Christmas presents is a piece of ‘art’ that my then six-year-old son made for me out of odds and ends from the cellar. He’d clearly put considerable effort into choosing, arranging and attaching the various hooks, skewers, screws, and bits of scrap metal to their wooden block background – and then, for some reason best known to himself, connecting these random articles with bits of string. I must have looked a little bemused when I opened it, because he said: ‘It’s art, Mummy.’ And I’m sure it is, although perhaps no one but his six-year-old self would agree. In fact, in the most recent house clear-out, his now 17-year-old self said: ‘Oh Mummy, do get rid of that thing – it’s hideous!’
It's true that its artistic merit is, shall we say, limited; and it’s arguably worse than useless, because every time it falls off its perch on my bookshelf, one of its metal protuberances makes a dent in our nice wooden floor. But get rid of it? Never! It was made with great endeavour, enthusiasm and love, and shall remain on my bookshelf forever.
I know I cannot expect a similar kind of blind appreciation for my 2025 Christmas present to you all, though I assure you that it too was made with great endeavour, enthusiasm and, yes, love! Love for reporting, and a keenness to make sure it really works for everyone; readers, preparers and all the other parties involved.
But I can promise that it was made with perhaps a little more skill and expertise than my precious artwork. Not least because, over the last three months while I’ve been nursing my brain back to health, it has benefited enormously from contributions from 50+ FTSE companies, technical and regulatory experts, auditors and investors, ably synthesised by my fantastic colleague, Hilary Eastman. I am enormously grateful to all of them, and especially to Hilary, for so generously sharing their time and considerable expertise with us.
So what is this labour of love that I dare offer as a present? After all, I do subscribe to the view that presents should be what you think the receiver might like, rather than what you think they ought to have.
It is a proposal for a new model for corporate reporting, for the age of AI.
The reason I think – hope! – you’ll like it (especially those of you who have to produce annual reports), is because, according to the feedback, it really could simplify reporting; making it easier and cheaper to produce, and far more useful to its readers, whether they be humans or machines. It could even (after the upheaval of restructuring everything in the first year or so), save companies around 10% of the costs of reporting each year!
And why it might even be a useful present rather than just a nice idea, is that at last, thanks to the good folks at the Department for Business and Trade and their ‘Modernisation of Corporate Reporting’ review, due to be launched in the new year, we have a genuine opportunity to make change happen. There have been plenty of very worthy efforts over the last decade or so to reform reporting, but until now, the combination of political will and practical urgency to ensure the good ideas are put into practice has been missing. So far, I’ve heard very positive noises from the DBT, to whom I promised the proposal before Christmas as a contribution to their thinking. And off it went yesterday, albeit without the wrapping and ribbon with which I now give it to you.
Now, I appreciate that a 20-page document may not sound like a very enticing Christmas present. But rest assured that it has a two-page executive summary, and the model itself is very simple in principle. I’ve set it out below, so you don’t even have to open your present to know what’s in it (although if you want to see Hilary’s beautiful diagram of the model, you do!). However, stakeholder feedback told us that where it gets complicated is how the model would work in practice; which is why half of the paper is an appendix, where this is explained in more detail. The paper also contains a summary of the model’s benefits and challenges, and a list of areas for further discussion.
Your Christmas present in summary
Our model* has four key points.
Codify the purpose of corporate reporting overall; and within that, the purpose of the annual report for different types of company.
Mandate that only material information should be included in the annual report, with materiality being determined by the purpose of the annual report for that type of company, and the needs of the principal stakeholder to whom it is reporting.
Mandate that the annual report should have two parts, disclosures (statements plus notes) and commentary, with guidelines on how to use AI in both cases. In essence, this takes the principle of today’s relationship between the financial statements/notes and their commentary (the results statement, usually included in the strategic report under the heading ‘financial review’), and applies it to all material disclosures and their commentary.
Mandate a dedicated section of the corporate website in the top-level navigation – ‘Reports and disclosures’ – where companies publish, in three clearly marked subsections: the annual report; other mandatory disclosures; and voluntary disclosures.
* While our focus is on listed companies, since we have most experience here, the principles would apply equally well to any type of company required to report.
A caveat for policy-making and regulatory recipients: we need a single body to be responsible for reporting regulation
The biggest barrier to simplification is that reporting requirements come from multiple bodies. For real change to happen – whether from our model or any other – reporting requirements must be brought together under the remit of one body. A little challenge to ponder over the holidays!
You can read the full paper here.
Or, if you fancy a bracing alternative to yuletide viewing, you can watch our 45-minute webinar on the subject from 4 December – with excellent contributions from Jonathan Labrey, who leads the IFRS Foundation’s integrated reporting effort, and Ida Woodger, Group Company Secretary of Intertek.
I do hope you like your present, but don’t worry, I shan’t be scouring my inbox for thank-you letters. Although I would absolutely love to receive any feedback and comments you’d care to send to claire@falconwindsor.com! Our model is a work in progress, and I’m aiming to gather even more input in the new year to strengthen it before the review formally begins.
On behalf of everyone at Falcon Windsor, I wish you all a very peaceful and happy Christmas.