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The 73 FPPP criteria

Nine areas, each mapped to the UK Listing Rules and to the illustrative objectives in ICAEW TECH 14/14CFF Appendix 1. Gate items are the ones a sponsor cannot give the FPPP opinion without.

FPPP v1 (UKLR, 2026) · rules current as of 2026-10-30

Group level, or every entity

13 of the 73 criteria have to hold at every entity inside the IPO perimeter, not at the holding company alone; the other 60 are satisfied once, at the top. That distinction is the multiplier nobody budgets for — one policy is one piece of work, and the same policy adopted at eleven subsidiaries is eleven board meetings. It is also why readiness for one of these is the group's weakest entity rather than its average.

01

Directors' risk assessment of FPP

ICAEW §A · 9 criteria

Whether the directors can identify and manage the risks that bear on the group's financial position and prospects — and have written that assessment down.

1.1

Risk management framework

Compliance & Risk

The group must have a written framework setting out how risk is identified, how it is assessed, how it is mitigated and on what cycle the framework itself is revisited.

UKLR 24.3.2R(5)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §A
What discharges it

framework document — Sets out how risks are identified, assessed, owned, mitigated and escalated, and on what cycle the process itself is reviewed.board approved

1.2

Group risk register

In free scanCompliance & Risk

The group must keep a register of its current risks and refresh it on a stated cycle, rather than assemble one when somebody asks.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A(b)
What discharges it

register — A current group risk register giving, for each risk, likelihood, financial impact, owner and mitigation.no older than 6 months

1.3

Risk categories covered

In free scanCompliance & Risk

Risk identification must reach operational, financial, strategic and regulatory risk, and climate-related risk alongside them — the category the TCFD recommendations address.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A(c)
What discharges it

register — Each of the five categories is represented by at least one identified risk, and the register shows which category each risk belongs to.

1.4

Risk assessment methodology

Compliance & Risk

How likelihood and financial impact are scored must rest on a written methodology rather than on whoever is filling the register in.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A
What discharges it

process document — Defines the likelihood and financial-impact scales, the thresholds between them, and how a combined rating is derived.

1.5

Risk owners

In free scanCompliance & Risk

Every risk on the register must name the individual accountable for it.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A
What discharges it

register — Every risk names an accountable individual.named owner

1.6

Mitigation actions

In free scanCompliance & Risk

Every risk must carry mitigating action that is written down, and progress against that action must be tracked.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A
What discharges it

register — Each risk carries mitigating actions with a status and a review date.operated if triggered

1.7

Board and committee challenge

Compliance & Risk

The board, and the committee charged with audit and risk, must review and challenge the risk process itself at regular intervals, and that review must be recorded.

UKLR 24.3.2R(5)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(s)ICAEW TECH 14/14CFF App.1 §B(b)
What discharges it

committee minutes — Minutes record the committee reviewing the risk register and challenging management on it — not merely receiving it.no older than 12 months

1.8

FPP-relevant risk factors

In free scanCompliance & Risk

Risks bearing on the company's financial position and prospects must be marked as such and tied to the procedures that address them.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A(b)
What discharges it

register — Risks bearing on financial position and prospects are marked as such and each maps to the named procedure that addresses it.

1.9

Directors' FPPP risk assessment

GateBoard / Company Secretary

The directors must assess the risks to financial position and prospects across all seven areas covered by this pack — the high-level reporting environment, forecasting and budgeting, the management reporting framework, significant transactions and the exposure they carry, strategic projects, financial accounting and reporting, and the IT environment — and record how the company's procedures answer each of them.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §A(c)
What discharges it

framework document — A single directors' FPPP risk assessment addressing each of the seven areas by name, and stating for each the procedures relied upon.board approved

02

High-level reporting environment

ICAEW §B · 12 criteria

The governance structure, the people and the control environment underneath financial reporting: board and committees, the finance function, internal control, internal and external audit.

2.1

Board skills matrix

Board / Company Secretary

The board must hold financial and sector experience among its members, recorded in a skills matrix.

UKLR 24.3.2R(5)UKLR 24.3.2R(4)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(b)UK Corporate Governance Code, Provision 23
What discharges it

matrix — Maps each director against financial and sector-specific skills, and identifies the gaps the nomination committee is recruiting against.

2.2a

Audit committee body

GateBoard / Company Secretary

A body must be responsible for performing the audit committee functions required by DTR 7.1.3R: monitoring the financial reporting process, the effectiveness of the internal control and risk management systems, and the statutory audit of the annual and consolidated financial statements.

DTR 7.1.1R–7.1.3RUKLR 2.2.1R — Listing Principle 1UKLR 24.3.2R(4)FCA Handbook, DTR 7.1
What discharges it

board minutes — The board resolution establishing the body and delegating the DTR 7.1.3R functions to it, together with the disclosure naming the body and its members required by DTR 7.1.5R.board approved

2.2

Committee terms of reference

In free scanBoard / Company Secretary

Written terms of reference, approved by the board, must exist for the audit and risk committee and for the remuneration and nomination committees.

UKLR 2.2.1R — Listing Principle 1UKLR 24.3.2R(4)DTR 7.1.1R–7.1.3RUK Corporate Governance Code, Provision 14
What discharges it

terms of reference — Signed terms of reference for each of the three committees, stating composition, independence requirements, quorum and delegated authority.board approved

2.3

ICFR framework

GateEvery entityCompliance & Risk

Internal control over financial reporting must be set out in a documented framework rather than existing only as practice.

UKLR 2.2.1R — Listing Principle 1UKLR 20.2.4ARICAEW TECH 14/14CFF App.1 §B(n)
What discharges it

framework document — Identifies the key financial reporting controls, names a control owner for each, and states how design and operating effectiveness are assessed and on what cycle.

2.4

Delegation of authority

Every entityCFO / Finance

Approval limits for procurement, payments and commitments must be set out in a delegation of authority matrix and enforced in the systems that process them.

UKLR 2.2.1R — Listing Principle 1UKLR 20.2.4ARICAEW TECH 14/14CFF App.1 §B(g)
What discharges it

matrix — Approval limits for procurement, payments and commitments, by role and value band, stating for each how the limit is applied — enforced in the system, or by a named compensating control where the system cannot carry it.board approved · must have operated: Either system configuration or a workflow export showing the limits enforced, or a sample of recent approvals at and above each threshold showing the matrix was the one actually followed.

2.5

Finance function resourcing

CFO / Finance

The finance function must be staffed to the accounting and reporting complexity it carries, with roles, reporting lines and qualifications recorded from the CFO down to the people who keep the records.

UKLR 24.3.2R(5)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(d)
What discharges it

org chart — An organisation chart for the finance function showing who does what and who reports to whom, with qualifications against the names and any unfilled post marked as unfilled.

2.6

Whistleblowing policy

Every entityCompliance & Risk

There must be a whistleblowing route with a documented escalation path, and staff must have been told about it.

UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(m)
What discharges it

policy — Names the reporting channel, protects the reporter from retaliation, and states how reports are escalated, investigated and tracked to conclusion.board approved · must have operated: Evidence of communication to staff — intranet posting, induction pack or training record.

2.7

Control deficiency remediation

Compliance & Risk

Internal control deficiencies must be identified, reported and put right under a documented process.

UKLR 20.2.4ARUKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(o)
What discharges it

process document — States how deficiencies are logged, rated for severity, communicated, assigned and cleared, with timescales and an escalation threshold to the audit committee.

2.8

Internal audit

Internal Audit

There must be an internal audit function, or a written explanation of why there is none naming the controls that compensate for it.

UKLR 2.2.1R — Listing Principle 1UKLR 20.2.4ARICAEW TECH 14/14CFF App.1 §B(q)UK Corporate Governance Code, Provision 26
What discharges it

terms of reference — An internal audit charter and annual plan approved by the audit committee — or, where there is no function, a board-approved explanation naming the compensating controls relied upon.board approved

2.9

External audit recommendations

CFO / Finance

Recommendations from the external auditor must be handled under a documented process that follows them through to completion.

UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(p)
What discharges it

process document — States how management-letter points are assigned, tracked and reported to the audit committee, with the current status of open points available.

2.10

Accounting records

Every entityCFO / Finance

Accounting records must be kept current enough to produce management information while that information is still timely.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §B(j)
What discharges it

management accounts — Records support production of management information within the stated close timetable.must have operated: For the most recent closed month: the trial balance, and the key balance-sheet reconciliations, showing they were completed and reviewed.

2.11

Statutory-to-management reconciliation

CFO / Finance

The route from the statutory financial position to the management accounts must be reconciled under a documented process.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §B(k)
What discharges it

process document — A documented reconciliation between the management accounts and the statutory IFRS position, with the bridge for the most recent period retained and explained.

03

Forecasting and budgeting

ICAEW §C · 8 criteria

Whether the group can forecast well enough to manage market expectations and support a working capital statement — the one area where the evidence is a model, not a document.

3.1

Annual budgeting process

In free scanCFO / Finance

The annual budget must be built under a documented process, running from the setting of assumptions through to board approval.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §C(b)
What discharges it

process document — Sets out the budget cycle with dates, responsibilities, the assumption-setting step, the challenge and iteration stages, and the board approval point.

3.2

Controlled financial model

GateCFO / Finance

The financial model must have its logic and its assumptions documented and its versions controlled, so that any figure in circulation can be traced back to one file.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §C(d)
What discharges it

financial model — A single controlled master version, with an assumptions sheet, a change log, and the model's logic documented well enough for a reviewer to follow a number from driver to output.named owner

3.3

Re-forecasting

CFO / Finance

Forecasts must be revisited under a process that responds to actual performance and to changes in trading conditions.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §C(c)
What discharges it

process document — States the re-forecast cadence and the triggers for an out-of-cycle re-forecast, and shows how actuals feed back into the model.must have operated: The two most recent re-forecasts and what changed between them.

3.4

Sensitivity and scenario analysis

CFO / Finance

Sensitivity and scenario analysis must be documented, and must cover the drivers the business actually turns on, such as input costs, exchange rates and volumes.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §C(c)ICAEW TECH 14/14CFF App.1 §C(d)
What discharges it

financial model — Downside and upside scenarios run on the declared key drivers, with the mechanics visible in the model rather than pasted in as values.

3.5

Variance analysis

CFO / Finance

Actual results must be set against budget and forecast with management commentary, and put before the board while the comparison is still current.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §C(g)
What discharges it

report pack — Actual against budget and against forecast, with written explanation of material variances in both directions, in a pack the board demonstrably received.no older than 3 months

3.6

Board approval of the budget

In free scanCFO / Finance

Senior management and the board must approve the budget and the forecasts before the period they cover has begun.

UKLR 24.3.2R(5)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §C(f)
What discharges it

board minutes — Board approval of the budget recorded on a date before the start of the financial period it covers.board approved

3.7

Analyst forecasts and market expectations

Investor Relations

Monitoring of analyst forecasts, and the management of market expectations, must rest on a documented process.

UKLR 2.2.1R — Listing Principle 6UK MAR Art. 17(1)FCA Handbook, DTR 2.2; UK MAR Art. 17
What discharges it

process document — Names who tracks consensus, how the company's own forecast is compared against it, and the threshold at which a trading update or announcement is considered.

3.8

Replanning on forecast

Strategy

There must be a process for adjusting plans and moving resources when monitoring against budget and forecast calls for it.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §C(h)
What discharges it

process document — A documented process for acting on forecast monitoring: what triggers a replan, who decides, and how a reallocation of resource is recorded.operated if triggered

04

Management reporting framework

ICAEW §D · 6 criteria

The quality, timeliness and content of the financial and operational information the board actually receives — including between reporting dates.

4.1

Monthly management accounts

GateEvery entityCFO / Finance

A monthly management pack must be produced covering profit and loss, cash flow, the balance sheet, working capital, the KPIs and the performance of each subsidiary reported separately.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §D(b)
What discharges it

management accounts — A monthly pack containing all six elements, with divisional reporting for every entity in the IPO perimeter.per entity

4.2

Reporting timetable

CFO / Finance

The management pack must appear to a defined timetable, at the same point in every period.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §D(b)
What discharges it

process document — A published close calendar, plus the actual issue date of each of the last six packs against it.must have operated: Issue dates for the last six periods, showing whether the calendar was met.

4.3

Segment KPIs

In free scanStrategy

The KPIs must be defined and written down for each business segment.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §D(a)
What discharges it

process document — For each segment, each KPI with its formula, data source and owner — and, for any non-IFRS measure, the reconciliation to the nearest IFRS measure.named owner

4.4

Out-of-cycle escalation

Every entityCFO / Finance

Material financial events arising between monthly reporting dates must have a defined escalation route.

UKLR 2.2.1R — Listing Principle 1UK MAR Art. 17(1)ICAEW TECH 14/14CFF App.1 §D(c)
What discharges it

process document — States the materiality threshold, the escalation route to the board, and the timescale — with the link to the inside-information assessment made explicit.

4.5

Management-to-IFRS reconciliation

CFO / Finance

There must be a documented route from the management accounts to the statutory IFRS accounts, showing what changes between the two.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §B(k)
What discharges it

process document — The documented reconciliation with the most recent bridge retained, showing each reconciling item and who reviewed it.

4.6

Board information between dates

Board / Company Secretary

The board must hear about events with a material financial impact as they arise, rather than at the next reporting date.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §D(c)
What discharges it

board minutes — A documented route by which a material financial event reaches the board between scheduled reporting dates — the trigger, the threshold, and who is responsible for raising it.operated if triggered

05

ESG, climate and sustainability reporting

ICAEW §A · 9 criteria

Procedures for identifying, managing and reporting environmental, social and governance matters — including how climate risk reaches the risk register, the forecasts and the impairment models.

5.1

ESG oversight mandate

ESG

Oversight of sustainability and climate matters must sit with the board or with a named committee, under a written mandate.

UKLR 2.2.1R — Listing Principle 1DTR 7.2.2R–7.2.7RTCFD Recommendations — governance
What discharges it

terms of reference — Terms of reference that give a named body oversight of sustainability and climate, and minutes showing it has used them.board approved

5.2

Environmental policy

Every entityESG

The group must have an environmental policy that the board has approved and that the operating companies work to.

UKLR 2.2.1R — Listing Principle 1Written here — no UK listing rule requires an environmental policy; this is what a prospectus and an investor’s ESG review ask for
What discharges it

policy — An environmental policy carrying a board approval date, and evidence that each entity in the perimeter works to it.board approved · per entity

5.3

Health and safety policy

Every entityESG

The group must have a health and safety policy, applied at each operating subsidiary rather than only at the holding company.

UKLR 2.2.1R — Listing Principle 1Written here — health and safety is home law rather than a UK listing rule; this is what a prospectus and an investor’s ESG review ask for
What discharges it

policy — A health and safety policy, with evidence of its use at each material operating entity rather than only at the holding company.

5.4

Business ethics and anti-corruption

Every entityCompliance & Risk

The group must have a code of business ethics and anti-bribery procedures, formally adopted rather than merely drafted.

UKLR 2.2.1R — Listing Principle 1UKLR 2.2.1R — Listing Principle 4Bribery Act 2010, s.7
What discharges it

policy — A code of ethics and anti-bribery procedures adopted at every entity in the IPO perimeter, each carrying the date it was adopted.board approved · per entity

5.5

Climate risk in the risk matrix

In free scanESG

Climate-related risk must sit in the group's own risk register, with physical risk and transition risk identified separately.

UKLR 24.3.2R(5)TCFD Recommendations — risk management
What discharges it

register — A risk register in which physical and transition climate risk appear as separate entries, each traceable to the assessment behind it.

5.6

ESG in forecasts and impairment

CFO / Finance

Where climate and wider sustainability factors are material, they must be carried into the forecasts, the impairment reviews and the measurement of provisions.

UKLR 24.3.2R(5)TCFD Recommendations — strategy
What discharges it

financial model — Forecasts and impairment models in which the material climate and sustainability assumptions are stated on their own line rather than folded into an aggregate.

5.7

Climate disclosure data

ESG

Data for climate-related disclosure must be gathered under a defined process, with a named owner for each metric.

UKLR 2.2.1R — Listing Principle 1DTR 7.2.2R–7.2.7RUKLR 6.6.6R(8); TCFD Recommendations — metrics and targets
What discharges it

process document — A written data-collection procedure, one named owner per metric, the templates in use, and the checks a figure passes before it is published.named owner

5.8

Corporate governance statement

Board / Company Secretary

A corporate governance statement must be prepared for the annual report, describing the internal control and risk management systems used in financial reporting and the board diversity policy, or explaining the absence of one.

DTR 7.2.2R–7.2.7RFCA Handbook, DTR 7.2
What discharges it

process document — A draft governance statement that can be read against each applicable DTR 7.2 rule and Code provision, one at a time.

5.9

Sustainability reporting process

ESG

Preparing the sustainability section of the annual report must follow a documented process covering the calendar, the responsibilities and the approvals.

DTR 7.2.2R–7.2.7RDTR 4.1.3RUKLR 2.2.1R — Listing Principle 1UKLR 6.6.6R(8); UK SRS S1 and S2
What discharges it

process document — A written sustainability reporting procedure naming the calendar, the owners, the approval points, and where the underlying evidence is held.

06

Significant transaction complexity

ICAEW §E · 6 criteria

Procedures for transactions carrying significant accounting complexity, financial exposure or risk — including related party transactions, which are where a listing goes wrong quietly.

6.1

Significant transaction policy

In free scanLegal

There must be a written policy for identifying significant transactions, setting out what counts as one under the listing rules that apply to the company.

UKLR 7UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §E
What discharges it

policy — Defines what constitutes a significant transaction, states the class tests applied, and names who performs the assessment and when.board approved

6.2

Accounting and tax on complex deals

CFO / Finance

The accounting and tax consequences of complex transactions — acquisitions and disposals, joint ventures, financial instruments, related-party deals — must be assessed under a documented process.

UKLR 24.3.2R(5)UKLR 7ICAEW TECH 14/14CFF App.1 §E(a)
What discharges it

process document — States who assesses accounting and tax implications, at what point in the transaction, and how the assessment reaches the board before commitment.

6.3

External advisor engagement

Strategy

Engaging and managing outside advisers on complex matters must follow a documented process.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §E(f)
What discharges it

process document — Covers selection, scoping and approval of advisors, and states who is accountable for considering and acting on the advice received.

6.4

Transaction approval chain

In free scanCFO / Finance

Significant transactions must pass a defined approval chain: review by the CFO, then by the audit committee, then approval by the board.

UKLR 7UKLR 2.2.1R — Listing Principle 1DTR 7.1.1R–7.1.3RICAEW TECH 14/14CFF App.1 §B(g)
What discharges it

process document — Sets out the approval sequence with the threshold that triggers each stage.operated if triggered

6.5

Related-party transactions

Every entityLegal

Related-party transactions must be covered by documented procedures for identifying them, assessing them, approving them and disclosing them.

UKLR 8UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §E
What discharges it

register — A maintained related-party register plus the documented procedure covering identification, assessment against the threshold, approval, and disclosure.no older than 6 months

6.6

Listing-rule compliance monitoring

Legal

Someone must check that the rules on significant transactions are being kept to, and report anything that is not to the board.

UKLR 7UKLR 8UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §E(g)
What discharges it

process document — Names who monitors compliance, on what cycle, and how exceptions are reported to the board.named owner

07

Strategic projects and initiatives

ICAEW §F · 8 criteria

Oversight of the capital projects and initiatives with material financial consequences — appraisal, monitoring, tax, and getting them into the right accounting period.

7.1

Investment appraisal

Strategy

Major capital projects must pass an appraisal covering strategic fit, financial viability and risk, and must reach the board for approval.

UKLR 24.3.2R(5)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §B(h)
What discharges it

process document — Requires strategic fit, financial viability and risk assessment in every proposal, and names the approval threshold at which the board decides.board approved

7.2

Project management framework

Strategy

Projects must run inside a framework that sets milestones, budgets, timelines and a named owner for each.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(a)
What discharges it

framework document — Defines milestones, budget control, timelines and a named owner per project, with the route by which project reporting reaches the board.named owner

7.3

CapEx reporting

CFO / Finance

Capital expenditure reporting must show spend and commitments against the approved budget, and must reach the board on a regular cycle.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(b)
What discharges it

report pack — CapEx reporting showing actual spend AND outstanding commitments against approved budget, in a pack the board received.no older than 3 months

7.4

Contractor monitoring

In free scanStrategy

Approving contractors and suppliers, and monitoring how they perform, must follow a documented process.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(g)
What discharges it

process document — Covers approval and onboarding, and states how contractor performance is monitored against the scope and reported.

7.5

Asset economic lives

CFO / Finance

The economic lives of the major operating assets and of the infrastructure must be measured and formally reassessed under a defined process.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(f)
What discharges it

process document — States how economic lives are set and reviewed, and documents the basis for asset replacement decisions.

7.6

Project tax assessment

CFO / Finance

The tax consequences of a strategic project must be assessed and written up before the company commits to it.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(c)
What discharges it

process document — Requires a documented tax assessment before commitment, and names who performs and reviews it.

7.7

Project period cut-off

CFO / Finance

There must be a process that places strategic-project transactions in the accounting period they belong to.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(d)
What discharges it

process document — Sets out the cut-off procedure for project accruals, capitalisation and commitments, and who verifies it at each close.

7.8

Project reporting up to date

Strategy

Reporting on strategic projects must be kept current, rather than assembled at the point somebody asks for it.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §F(e)
What discharges it

report pack — The most recent project report, dated, showing status against milestones and budget.no older than 3 months

08

Financial accounting and reporting

ICAEW §G · 7 criteria

Compliance with IFRS and with the external reporting obligations of a listed company — including the market abuse machinery that has to work from day one.

8.1

IFRS accounting policies

GateEvery entityCFO / Finance

Accounting policies compliant with IFRS must be documented, approved by the board, and applied the same way at every entity in the group.

UKLR 24.3.2R(5)UKLR 20.2.4ARPRM 4.4.11R–4.4.13RICAEW TECH 14/14CFF App.1 §G(a)
What discharges it

policy — A group IFRS accounting policy manual, board-approved, with evidence it is the manual each perimeter entity actually applies.board approved · per entity

8.2

Standards monitoring

In free scanCFO / Finance

New and amended IFRS standards must be monitored, and the policy changes that follow from them communicated, under a defined process.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §G(c)
What discharges it

process document — Names who monitors standard-setting, how impact is assessed, and how policy changes are communicated to the entities that must apply them.named owner

8.3

Key judgements and estimates

CFO / Finance

The areas carrying the most judgement and estimation uncertainty — asset lives, impairment, provisions, revenue recognition, leases — must be identified and written up.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §G(d)
What discharges it

process document — A schedule of key judgements and estimates with, for each, the assumption used, the basis for it, and who approved it.

8.4

Reporting timetable and deadlines

CFO / Finance

Preparing the half-year and annual financial statements must run to a documented timetable with named roles, and must land inside the statutory deadlines.

UKLR 24.3.2R(5)DTR 4.1.3RDTR 4.2.2RICAEW TECH 14/14CFF App.1 §G(e)
What discharges it

process document — A reporting calendar working back from the DTR deadlines, with each step owned by a named individual and the review and approval gates marked.named owner

8.5

Disclosure committee

Board / Company Secretary

There must be a finance team, a disclosure committee and an audit committee, each with written terms of reference and a clear line of decision-making authority.

UKLR 2.2.1R — Listing Principle 1UK MAR Art. 17(1)DTR 7.1.1R–7.1.3RFCA Handbook, DTR 7.1; UK MAR Art. 17
What discharges it

terms of reference — Terms of reference for the disclosure committee, stating membership, quorum, decision-making authority, and how a candidate item of inside information reaches it.board approved

8.6

MAR and inside information

GateLegal

Market abuse procedures must be in place: insider lists kept and updated, a route for notifying dealings by persons discharging managerial responsibilities, and a process for identifying inside information and disclosing it to the market, holding announcements included.

UK MAR Art. 17(1)DTR 2.2.9GUKLR 2.2.1R — Listing Principle 6UK MAR Arts. 17–19
What discharges it

register — A maintained insider list, plus documented procedures for PDMR notifications and for assessing, escalating and disclosing inside information — including when to issue a holding announcement.named owner

8.7

External reporting ownership

Investor Relations

External reporting duties must be assigned to named individuals, with their deadlines tracked.

UKLR 24.3.2R(5)DTR 4.1.3RDTR 4.2.2RICAEW TECH 14/14CFF App.1 §G(e)
What discharges it

process document — Each external reporting obligation mapped to a named individual with its deadline, and a record of how compliance is monitored and delays investigated.named owner

09

IT environment

ICAEW §H · 8 criteria

The systems, controls and infrastructure that produce FPP information — access, segregation of duties, resilience, and the third parties the group depends on.

9.1

Cybersecurity policy

IT

There must be a documented cybersecurity policy and framework, in use and revisited on a regular cycle.

UKLR 2.2.1R — Listing Principle 1UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §H
What discharges it

policy — A cybersecurity policy with a stated review cycle and evidence of the most recent review.board approved · no older than 12 months

9.2

Logical access controls

Every entityIT

Access to the key financial applications must be restricted to the users authorised to hold it.

UKLR 24.3.2R(5)UKLR 2.2.1R — Listing Principle 1ICAEW TECH 14/14CFF App.1 §H(i)
What discharges it

system config — A current user access list for each key financial application, showing access restricted to authorised users, with joiners and leavers reflected.per entity

9.3

Segregation of duties

Every entityIT

User permissions must be set up with segregation of duties, documented, and reviewed on a cycle.

UKLR 2.2.1R — Listing Principle 1UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §B(i)ICAEW TECH 14/14CFF App.1 §H(i)
What discharges it

system config — A documented segregation-of-duties matrix, and a periodic access review that has actually been performed — with its outcome recorded, whether or not it raised anything.no older than 6 months · operated if triggered

9.4

Disaster recovery plan

IT

There must be a documented disaster recovery plan reaching every system the financial reporting depends on.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §H(f)
What discharges it

process document — A disaster recovery plan naming every system critical to financial reporting, with recovery objectives, and evidence it has been approved and communicated.

9.5

Disaster recovery testing

IT

Disaster recovery plans must be tested at intervals, with the results written down and the problems found put right.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §H(g)
What discharges it

test record — The most recent DR test record, with results, issues raised, and evidence those issues were addressed.no older than 12 months

9.6

Backup and restore

In free scanIT

Backup arrangements must be documented, and restoring from them must have been tested.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §B(r)
What discharges it

test record — Backup schedule and retention documented, plus a restore test record showing data was successfully recovered.no older than 12 months

9.7

Third-party IT providers

IT

Third-party IT and cloud providers must be contracted, assessed and monitored against defined performance standards.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §H(k)ICAEW TECH 14/14CFF App.1 §H(l)
What discharges it

contract — Signed contracts with the material IT and cloud providers, with service levels defined, plus the risk assessment covering data integrity and governance and evidence of performance monitoring.

9.8

Core financial systems documented

IT

The core financial systems — the ERP, the consolidation tools — must be reviewed, and the IT processes behind financial reporting documented, covering what goes in, what comes out, and the interfaces between them.

UKLR 24.3.2R(5)ICAEW TECH 14/14CFF App.1 §H(b)
What discharges it

process document — A system landscape document naming the core financial systems, their data inputs and outputs, and every interface between them — flagging which are automated and which are manual.

This is a readiness and gap assessment, prepared as a management tool. It is NOT an assurance opinion, NOT the reporting accountant's private FPPP comfort letter, NOT legal, tax or investment advice, and it does not make any company eligible to list or guarantee any outcome. The sponsor's opinion under UKLR 24.3.2R(5) can be given only by a sponsor, and the FPPP assurance opinion only by an appointed reporting accountant; nothing here substitutes for either. Rule citations are current as of the date shown and the UK listing regime changes — verify against the FCA Handbook before relying on any citation. Evidence tests for areas 1–4 and 6–9 are our considered interpretation of the ICAEW objectives, not an official checklist.