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.
Directors' risk assessment of FPP
ICAEW §A · 9 criteriaWhether the directors can identify and manage the risks that bear on the group's financial position and prospects — and have written that assessment down.
Risk management framework
Compliance & RiskThe 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.
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
Group risk register
In free scanCompliance & RiskThe group must keep a register of its current risks and refresh it on a stated cycle, rather than assemble one when somebody asks.
What discharges it
register — A current group risk register giving, for each risk, likelihood, financial impact, owner and mitigation.no older than 6 months
Risk categories covered
In free scanCompliance & RiskRisk identification must reach operational, financial, strategic and regulatory risk, and climate-related risk alongside them — the category the TCFD recommendations address.
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.
Risk assessment methodology
Compliance & RiskHow likelihood and financial impact are scored must rest on a written methodology rather than on whoever is filling the register in.
What discharges it
process document — Defines the likelihood and financial-impact scales, the thresholds between them, and how a combined rating is derived.
Risk owners
In free scanCompliance & RiskEvery risk on the register must name the individual accountable for it.
What discharges it
register — Every risk names an accountable individual.named owner
Mitigation actions
In free scanCompliance & RiskEvery risk must carry mitigating action that is written down, and progress against that action must be tracked.
What discharges it
register — Each risk carries mitigating actions with a status and a review date.operated if triggered
Board and committee challenge
Compliance & RiskThe 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.
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
FPP-relevant risk factors
In free scanCompliance & RiskRisks bearing on the company's financial position and prospects must be marked as such and tied to the procedures that address them.
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.
Directors' FPPP risk assessment
GateBoard / Company SecretaryThe 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.
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
High-level reporting environment
ICAEW §B · 12 criteriaThe governance structure, the people and the control environment underneath financial reporting: board and committees, the finance function, internal control, internal and external audit.
Board skills matrix
Board / Company SecretaryThe board must hold financial and sector experience among its members, recorded in a skills matrix.
What discharges it
matrix — Maps each director against financial and sector-specific skills, and identifies the gaps the nomination committee is recruiting against.
Audit committee body
GateBoard / Company SecretaryA 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.
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
Committee terms of reference
In free scanBoard / Company SecretaryWritten terms of reference, approved by the board, must exist for the audit and risk committee and for the remuneration and nomination committees.
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
ICFR framework
GateEvery entityCompliance & RiskInternal control over financial reporting must be set out in a documented framework rather than existing only as practice.
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.
Delegation of authority
Every entityCFO / FinanceApproval limits for procurement, payments and commitments must be set out in a delegation of authority matrix and enforced in the systems that process them.
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.
Finance function resourcing
CFO / FinanceThe 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.
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.
Whistleblowing policy
Every entityCompliance & RiskThere must be a whistleblowing route with a documented escalation path, and staff must have been told about it.
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.
Control deficiency remediation
Compliance & RiskInternal control deficiencies must be identified, reported and put right under a documented process.
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.
Internal audit
Internal AuditThere must be an internal audit function, or a written explanation of why there is none naming the controls that compensate for it.
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
External audit recommendations
CFO / FinanceRecommendations from the external auditor must be handled under a documented process that follows them through to completion.
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.
Accounting records
Every entityCFO / FinanceAccounting records must be kept current enough to produce management information while that information is still timely.
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.
Statutory-to-management reconciliation
CFO / FinanceThe route from the statutory financial position to the management accounts must be reconciled under a documented process.
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.
Forecasting and budgeting
ICAEW §C · 8 criteriaWhether 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.
Annual budgeting process
In free scanCFO / FinanceThe annual budget must be built under a documented process, running from the setting of assumptions through to board approval.
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.
Controlled financial model
GateCFO / FinanceThe 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.
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
Re-forecasting
CFO / FinanceForecasts must be revisited under a process that responds to actual performance and to changes in trading conditions.
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.
Sensitivity and scenario analysis
CFO / FinanceSensitivity and scenario analysis must be documented, and must cover the drivers the business actually turns on, such as input costs, exchange rates and volumes.
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.
Variance analysis
CFO / FinanceActual results must be set against budget and forecast with management commentary, and put before the board while the comparison is still current.
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
Board approval of the budget
In free scanCFO / FinanceSenior management and the board must approve the budget and the forecasts before the period they cover has begun.
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
Analyst forecasts and market expectations
Investor RelationsMonitoring of analyst forecasts, and the management of market expectations, must rest on a documented process.
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.
Replanning on forecast
StrategyThere must be a process for adjusting plans and moving resources when monitoring against budget and forecast calls for it.
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
Management reporting framework
ICAEW §D · 6 criteriaThe quality, timeliness and content of the financial and operational information the board actually receives — including between reporting dates.
Monthly management accounts
GateEvery entityCFO / FinanceA 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.
What discharges it
management accounts — A monthly pack containing all six elements, with divisional reporting for every entity in the IPO perimeter.per entity
Reporting timetable
CFO / FinanceThe management pack must appear to a defined timetable, at the same point in every period.
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.
Segment KPIs
In free scanStrategyThe KPIs must be defined and written down for each business segment.
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
Out-of-cycle escalation
Every entityCFO / FinanceMaterial financial events arising between monthly reporting dates must have a defined escalation route.
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.
Management-to-IFRS reconciliation
CFO / FinanceThere must be a documented route from the management accounts to the statutory IFRS accounts, showing what changes between the two.
What discharges it
process document — The documented reconciliation with the most recent bridge retained, showing each reconciling item and who reviewed it.
Board information between dates
Board / Company SecretaryThe board must hear about events with a material financial impact as they arise, rather than at the next reporting date.
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
ESG, climate and sustainability reporting
ICAEW §A · 9 criteriaProcedures for identifying, managing and reporting environmental, social and governance matters — including how climate risk reaches the risk register, the forecasts and the impairment models.
ESG oversight mandate
ESGOversight of sustainability and climate matters must sit with the board or with a named committee, under a written mandate.
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
Environmental policy
Every entityESGThe group must have an environmental policy that the board has approved and that the operating companies work to.
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
Health and safety policy
Every entityESGThe group must have a health and safety policy, applied at each operating subsidiary rather than only at the holding company.
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.
Business ethics and anti-corruption
Every entityCompliance & RiskThe group must have a code of business ethics and anti-bribery procedures, formally adopted rather than merely drafted.
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
Climate risk in the risk matrix
In free scanESGClimate-related risk must sit in the group's own risk register, with physical risk and transition risk identified separately.
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.
ESG in forecasts and impairment
CFO / FinanceWhere climate and wider sustainability factors are material, they must be carried into the forecasts, the impairment reviews and the measurement of provisions.
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.
Climate disclosure data
ESGData for climate-related disclosure must be gathered under a defined process, with a named owner for each metric.
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
Corporate governance statement
Board / Company SecretaryA 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.
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.
Sustainability reporting process
ESGPreparing the sustainability section of the annual report must follow a documented process covering the calendar, the responsibilities and the approvals.
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.
Significant transaction complexity
ICAEW §E · 6 criteriaProcedures for transactions carrying significant accounting complexity, financial exposure or risk — including related party transactions, which are where a listing goes wrong quietly.
Significant transaction policy
In free scanLegalThere must be a written policy for identifying significant transactions, setting out what counts as one under the listing rules that apply to the company.
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
Accounting and tax on complex deals
CFO / FinanceThe accounting and tax consequences of complex transactions — acquisitions and disposals, joint ventures, financial instruments, related-party deals — must be assessed under a documented process.
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.
External advisor engagement
StrategyEngaging and managing outside advisers on complex matters must follow a documented process.
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.
Transaction approval chain
In free scanCFO / FinanceSignificant transactions must pass a defined approval chain: review by the CFO, then by the audit committee, then approval by the board.
What discharges it
process document — Sets out the approval sequence with the threshold that triggers each stage.operated if triggered
Related-party transactions
Every entityLegalRelated-party transactions must be covered by documented procedures for identifying them, assessing them, approving them and disclosing them.
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
Listing-rule compliance monitoring
LegalSomeone must check that the rules on significant transactions are being kept to, and report anything that is not to the board.
What discharges it
process document — Names who monitors compliance, on what cycle, and how exceptions are reported to the board.named owner
Strategic projects and initiatives
ICAEW §F · 8 criteriaOversight of the capital projects and initiatives with material financial consequences — appraisal, monitoring, tax, and getting them into the right accounting period.
Investment appraisal
StrategyMajor capital projects must pass an appraisal covering strategic fit, financial viability and risk, and must reach the board for approval.
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
Project management framework
StrategyProjects must run inside a framework that sets milestones, budgets, timelines and a named owner for each.
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
CapEx reporting
CFO / FinanceCapital expenditure reporting must show spend and commitments against the approved budget, and must reach the board on a regular cycle.
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
Contractor monitoring
In free scanStrategyApproving contractors and suppliers, and monitoring how they perform, must follow a documented process.
What discharges it
process document — Covers approval and onboarding, and states how contractor performance is monitored against the scope and reported.
Asset economic lives
CFO / FinanceThe economic lives of the major operating assets and of the infrastructure must be measured and formally reassessed under a defined process.
What discharges it
process document — States how economic lives are set and reviewed, and documents the basis for asset replacement decisions.
Project tax assessment
CFO / FinanceThe tax consequences of a strategic project must be assessed and written up before the company commits to it.
What discharges it
process document — Requires a documented tax assessment before commitment, and names who performs and reviews it.
Project period cut-off
CFO / FinanceThere must be a process that places strategic-project transactions in the accounting period they belong to.
What discharges it
process document — Sets out the cut-off procedure for project accruals, capitalisation and commitments, and who verifies it at each close.
Project reporting up to date
StrategyReporting on strategic projects must be kept current, rather than assembled at the point somebody asks for it.
What discharges it
report pack — The most recent project report, dated, showing status against milestones and budget.no older than 3 months
Financial accounting and reporting
ICAEW §G · 7 criteriaCompliance with IFRS and with the external reporting obligations of a listed company — including the market abuse machinery that has to work from day one.
IFRS accounting policies
GateEvery entityCFO / FinanceAccounting policies compliant with IFRS must be documented, approved by the board, and applied the same way at every entity in the group.
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
Standards monitoring
In free scanCFO / FinanceNew and amended IFRS standards must be monitored, and the policy changes that follow from them communicated, under a defined process.
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
Key judgements and estimates
CFO / FinanceThe areas carrying the most judgement and estimation uncertainty — asset lives, impairment, provisions, revenue recognition, leases — must be identified and written up.
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.
Reporting timetable and deadlines
CFO / FinancePreparing the half-year and annual financial statements must run to a documented timetable with named roles, and must land inside the statutory deadlines.
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
Disclosure committee
Board / Company SecretaryThere 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.
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
MAR and inside information
GateLegalMarket 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.
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
External reporting ownership
Investor RelationsExternal reporting duties must be assigned to named individuals, with their deadlines tracked.
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
IT environment
ICAEW §H · 8 criteriaThe systems, controls and infrastructure that produce FPP information — access, segregation of duties, resilience, and the third parties the group depends on.
Cybersecurity policy
ITThere must be a documented cybersecurity policy and framework, in use and revisited on a regular cycle.
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
Logical access controls
Every entityITAccess to the key financial applications must be restricted to the users authorised to hold it.
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
Segregation of duties
Every entityITUser permissions must be set up with segregation of duties, documented, and reviewed on a cycle.
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
Disaster recovery plan
ITThere must be a documented disaster recovery plan reaching every system the financial reporting depends on.
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.
Disaster recovery testing
ITDisaster recovery plans must be tested at intervals, with the results written down and the problems found put right.
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
Backup and restore
In free scanITBackup arrangements must be documented, and restoring from them must have been tested.
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
Third-party IT providers
ITThird-party IT and cloud providers must be contracted, assessed and monitored against defined performance standards.
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.
Core financial systems documented
ITThe 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.
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.