FRC Feedback on Digital Reporting Discussion Paper

On 15 May 2025 the Financial Reporting Council (FRC) published a Feedback Statement in response to its discussion paper on “Opportunities for future UK digital reporting”, which was published in August 2024.

The FRC notes that since 2011 UK regulators, agencies and government departments have required “filers” to report financial and non-financial information in a digital format with increasing frequency. They identify 2025 as the start of a “new phase” in this area, with regulators considering significant and substantial changes to their digital filing requirements.

Summary of responses

The FRC received 29 responses to the discussion paper from a range of stakeholders (including, for example, software and platform providers, auditors and their trade bodies and issuers) and a high level of support for digital reporting across the responses.

• The stakeholders recognised the value of working collaboratively to solve the challenges of the next phase of digital reporting in the U.K, with the common aim of reducing the complexity and costs of digital reporting for preparers.
• There was a focus on the “trade-offs” between meeting UK-specific requirements and maintaining comparability amongst UK (listed and non-listed) and international requirements.
• Some respondents recognised the value of assurance in digital reporting to improve trust and data quality and conversely there were concerns about the costs and burden of assurance on smaller entities. The responses, however, stressed the value of defining materiality specific to tagging and (if relevant) ensure assurance processes use (or align with) existing auditing or assurance frameworks.
• The respondents requested improved guidance and supporting materials to help them understand and meet their digital reporting requirements, and in particular illustrative examples to demonstrate what is being asked of preparers.

Next steps

The FRC states that no specific decisions will be taken this year as a result of the discussion paper and there is no commitment to a timeline for possible changes but the responses will inform thinking about policy and ongoing service development. 

If you would like to discuss any of the points raised in the FRC’s Feedback Statement, please speak to your usual Burges Salmon contact, Nick Graves (Head of the Corporate Department), AJ Venter (Partner, Corporate and M&A) or Charlotte Hamilton (Senior Associate, Corporate and M&A).