Post # 104
September 21, 2026
Claire Bodanis
In this supernumerary blog, Claire gives an overview of the UK Government’s Modernising Corporate Reporting consultation (published on 7 September), along with FW’s high-level thoughts on it so far.
I’m glad I’m 51. Why? Because my career in corporate reporting so far has taken me from a simpler time – before corporate websites really got going and the annual report (nice and short) was the pinnacle of corporate comms – to today’s complex world of digital platforms and technologies, generative AI, and an annual report that has become, due to the explosion of regulation, a rather messy conglomeration of different agendas.
And here I am, with 25 years’ experience to draw on, and the UK Government has launched a once-in-a-generation opportunity to rethink reporting, starting from its purpose. What better time for a UK corporate reporting geek to be alive?! Because what hasn’t changed in all these years – and what’s guided everything I’ve done and thought about reporting and always will – is that purpose.
I’ve attached Falcon Windsor’s ‘guided by purpose’ thoughts on the MCR as a separate paper, to prevent this blog from breaking all acceptable word counts. Our one-liner on the proposals closest to my heart, namely those for changing the annual report’s structure and content, is: ‘right direction, but a way to go to the destination?’ And you’ll find in the attached some initial ideas on how the proposals might be adapted to get us closer. We’ll be following that up with thoughts on more specific points in the MCR – particularly the comms/digital questions – in due course.
Here, I’ll give you a brief summary of what the MCR covers, and some thoughts on how to respond. And I hope you all will, because the more people who take part and contribute their views, the better the outcome will be – all the more important since we’ll probably have to live with it for a very long time.
I know from the lovely folks at the Department for Business, Innovation, Science and Trade (BIST) that they really do want to hear from as many people as possible – especially companies and the investment community – and feedback really will affect the outcome.
What is the MCR?
Launched by the Department for Business, Innovation Science and Trade (BIST) on 7 September, the Modernising Corporate Reporting consultation is a set of proposals to change how UK companies report. Together they offer a ‘once-in-a-generation opportunity to reset the UK’s corporate reporting framework’, and should contribute to its commitment to ‘reduce administrative burdens by 25%’.
Its aim is to ‘tackle problems that arise from too much reporting, from too many companies, producing too little material information for investors and creditors’.
Key proposals include:
A clear purpose for the annual report – in short, financially-material, decision-useful information for investors and creditors
Simplifying which companies must report what
A lighter reporting burden for SMEs
Making the UK’s financial reporting law clearer and more coherent
Simplifying and streamlining the strategic report
Simplifying corporate governance and remuneration reporting
A new ‘Reporting Gateway’ function within BIST, to ensure that any future proposals for reporting requirements are in line with the annual report’s purpose.
The MCR also seeks views on digital communications, including use of the corporate website, tagging, virtual AGMs, and the role of AI tools.
How to respond – consultation closes on 30 November
The BIST team are genuinely keen to hear from as many people as possible, and, despite the consultation’s comment about using AI to analyse the responses, We’ve been told that every response will be read by a BIST person before AI gets to look at it. So it is worth the effort! Here’s how to have your say.
Online survey: the consultation has 60 questions structured by chapter. You don’t have to respond to them all. Perhaps consider answering the first two, about the purpose of the consultation and the annual report itself; then pick those most relevant to you; and finally consider the last question, which is a general request for any other considerations/thoughts you might have about corporate reporting.
Respond by email to mcr.review@businessandtrade.gov.uk. You can submit whatever you like; either answer the survey questions, or give a free-form response.
Take part in a (corporate) stakeholder workshop – register your interest by emailing Alex Brady alex@falconwindsor.com. Falcon Windsor is running workshops with the UK Chartered Governance Institute in late October/early November to gather feedback for BIST, and to enable corporates to share their thoughts and develop their ideas. You can respond to the consultation without going to a workshop of course, but we’d love you to join us, and will be compiling a feedback paper from the sessions for BIST.
Responses must be in by 30 November.
Some ideas for corporates on preparing a response
A number of people have asked us for ideas on how to reach a ‘company view’ and whether it’s better to respond individually or through an industry body. Here are some suggestions.
Read the consultation and draft your own overarching view – don’t feel obliged to stick to the questions (and feel free to take inspiration from my reflections attached if you like!).
Gather internal feedback from those involved in reporting.
Gather feedback from the Board, and draw their attention to questions that directly affect them.
Have a look at the UK Sustainable Investment and Finance Association’s guide to responding to a consultation – it’s really helpful if you’re wondering how to shape your response.
Your own submission vs an industry body – BIST are looking for as many contributions as possible, so it’s worth producing your own. You may also want to contribute to an industry submission, for example the GC100 for FTSE 100 legal/co sec people; but, while it may carry weight, it will also by its nature have to be more general to cover everyone’s interests, and may miss out some of your specific thoughts or concerns.