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FPPP post-mortems8 October 2026

Where the procedures failed, and what would have caught it

A casebook, not a news feed. Each entry takes a case where a regulator, a court or the company itself has said that financial position and prospects procedures fell short, and names the criterion in the pack whose evidence test addresses it.

Archived edition — a finding may have been appealed or overturned since. Read the current one

The takeaway

The watch found no concluded enforcement or restatement case in this window that an authority has tied to a failure of financial position and prospects procedures at a listed or recently listed company. The one eligible item is the FCA's restatement of its own disclosure expectations for working capital statements and risk factors.

  • PMB 66, published 30 September 2026, finalises technical notes on prospectus disclosure and on working capital statements and risk factors, per the FCA.
  • The FCA has not identified any company in these items as having fallen short; the notes set the standard rather than report a breach.
  • Everything else fetched was either not about listed issuers, not a concluded finding, or, in the case of the FRC news page, navigation text with no article content.

Cases published 2 to 8 October 2026 · mapped to the criteria that address them

This edition searched for concluded regulatory findings, court outcomes and company statements showing that a listed or recently listed company's financial position and prospects procedures (FPPP) — the work a London Main Market listing requires under UKLR 24.3.2R(5) — had demonstrably failed. Almost nothing on the fetched list meets that test. The FCA items were largely speeches, consultations and authorisation notices about firms that are not listed issuers; the FRC news page returned navigation text rather than article content; and the RNS summaries were routine trading updates, results notices and AGMs. One item does touch the FPPP ground directly: the FCA's Primary Market Bulletin 66 and its associated technical notes on working capital statements and risk factors. It is treated below as a procedural finding about where listing document disclosure goes wrong, not as a case against any named company.

Searched the FCA news and publications feeds, the FRC news index, and the RNS/PRN newswire summaries for 2–8 October 2026. The FCA feed returned whistleblowing commentary, a capital markets reform speech, a practitioner survey, board appointments, the crypto authorisation gateway, several insolvency and fraud notices about non-listed firms, CFD and money mule items, and various consultations. The FRC news page returned only site navigation strings and no article content. The newswire carried routine trading updates, results notices and AGM announcements, with no restatement, material weakness, suspension for late accounts, or profit warning accompanied by an authority finding. Nothing in the window meets the editorial test, so this edition is short by design.

1. Working capital statements that do not stand up to the disclosure standard expected at admission

The FCA's Primary Market Bulletin 66, published on 30 September 2026, finalises two technical notes: TN 619.3 on disclosure requirements under the Prospectus Rules for admission to trading on a regulated market and on specialist issuers, and TN 321.5 on working capital statements and risk factors. The FCA describes PMB 66 as the point at which those technical notes are finalised following its earlier guidance consultation, and FG26/8 confirms the Knowledge Base has been updated with that guidance, including amendments to the technical note on working capital statements and risk factors and to the guidelines on prospectus disclosure. The FCA has not, in these items, made a finding against any named company. What the items establish is that the regulator has restated and reissued its expectations for the working capital statement and for risk factor disclosure — the two parts of a listing document on which the FPPP confirmation most directly depends — which is the standard against which a CFO or company secretary should read their own draft. Any claim that a particular issuer's procedures failed would require a separate finding by an authority, and none appears in the fetched material.

What would have caught it: A working capital statement built to the finalised TN 321.5 guidance, and risk factors drafted against the same note, tested against the FCA's own published expectations before the document is submitted rather than after.

Touches ra-1, ra-2, re-1, re-2 — check yours · run the free scan

Sources

It was found in their procedures. Is it open in yours?

Every case above names the criteria it touches. The free scan walks 15 of the 73 across all nine FPPP areas, checks your answers against each other, and tells you where they contradict. It runs entirely in your browser — nothing is sent anywhere, and nothing is stored.

Run the free scan →Read all 73 criteria

Published Thursdays. This is a casebook rather than a news feed: an older case that has not been covered is as welcome as a recent one. Compiled from public regulatory notices, court judgments and companies’ own announcements, and cited to them. It is not legal advice, not investment advice, and not a comment on any company’s prospects or securities.