The free FPPP self-scan
15 of the 73 criteria, covering all nine FPPP areas. It takes about ten minutes, and it will contradict you where your own answers collide.
Before you start
This finds what is missing. It does not grade you.
Most of what a first FPPP pass turns up is not failure — it is requirements nobody had put on the list yet, because the company was not a listed company when the list was written. Finding them now is the cheap version. Finding them in a reporting accountant’s phase 2 is not.
Nobody is finished at this point, and the FCA says so.
A company does not reach its listing with every procedure complete. The FCA’s own guidance to sponsors — FCA TN 708.4 on “the meaning of ‘established’” — says that when the confirmation under UKLR 24.3.2R(5) is given, not all necessary procedures, systems and controls will have been operated. What is required at that date is that they are designed, documented, approved, communicated, and that a plan the sponsor has reviewed covers the rest. So the useful question is not whether you are at 100%. It is whether you can say precisely what is missing, and who is closing it.
The criteria that decide it are not in this scan.
7 of the 73 are pass/fail: a sponsor cannot give the confirmation while one is open, so they are the items that cannot be left until later. That does not make them the hardest, and missing one says nothing damning — they set the order of work rather than the quality of the company. This scan asks none of them. So it will not tell you whether you would pass, and it does not guess: it reports what it did ask, and where your answers contradict each other. All 7 are published in full at /criteria, and they are what the paid diagnostic runs.
What this costs, and what it does not cover.
This scan is free and asks 15 of the 73 criteria. All 73 are published in full, free, with their rule cites and evidence tests, at /criteria. The paid diagnostic is the same criteria applied to your answers with priority, effort and sequencing — and you can read a complete worked example of it, on an invented company, without buying anything.
Which listings this applies to. The FPPP confirmation exists because a sponsor has to give it, and a sponsor is required for equity shares in the commercial companies category — the ordinary Main Market route. It is not required for depositary receipts (GDRs) or for an international secondary listing, where no sponsor is appointed, and there the rule cited above does not bind you — we would rather say that than let you assume it does. Less falls away than that suggests, though. On both routes the board still confirms to the FCA that adequate procedures, systems and controls are in place (UKLR 20.2.4AR, required of every first-time applicant), UK MAR still governs inside information and insider lists, and the procedures below are what a bank’s and a law firm’s due diligence examines and what a working capital statement rests on. On AIM the requirement changes hands rather than disappearing: the company itself declares on its application form that it has procedures for judging its financial position and prospects.
This is a self-assessment, and a sponsor will not accept it as evidence. What it can do is catch the places where your own answers do not hold together — claiming a process that depends on something you have told us you do not have. That is what a reporting accountant does on day one, and it needs no documents.
Your listing route
Which rules bind you depends on how you list. This changes the label on each criterion below — never the questions. GDRs or a direct listing: what differs →
Listing route: not decided
Scored and labelled as a direct share listing (ESCC), the strictest route, because no route was chosen. Choosing one changes the labels on each criterion.
Your company
Three facts about the company that change what a rule means for it. They change the notes on this page — not the questions, and not the verdict: none of the criteria asked here is a gate. Leave any you cannot answer yet.
Is the listing company incorporated in the UK?
The company whose shares are listed, or whose shares stand behind the certificates.
Which framework are the last three years' statutory accounts in?
It decides whether the historical financial information in the prospectus has to be restated.
Which body oversees the financial reporting and the audit today?
The body, or bodies, that monitor the financial reporting, internal control and the statutory audit.
The transaction
Continue from your workbook
If you have run this before and kept the Excel export, open it here: your answers come back, along with the Status, Owner and Target date columns you filled in yourself. The file is read in this tab — it is not uploaded, and there is nowhere here to put it if it were.
How far has each one got?
- Not started
- Nothing written down yet.
- Described
- Written, approved and communicated, with a plan to put it into use. This is the bar FCA TN 708.4 sets for the sponsor's confirmation, so it counts as met here.
- Implemented
- In use. More than the confirmation asks for at this date.
- Tested
- It has run and someone has checked the output — the state that produces evidence a reporting accountant can look at.
- Unsure
- You do not know where this stands.
- N/A
- It does not apply to this group, and it comes out of the counts entirely.
Described, implemented and tested all count as met, and count the same. FCA TN 708.4 says that at the sponsor's confirmation not all procedures will have been operated — what is needed is that they are designed, documented, approved and communicated, with a reviewed implementation plan. Anything past that is better than the confirmation requires, and this scan says so rather than weighting it higher.
Directors' risk assessment of FPP
0 / 5Whether the directors can identify and manage the risks that bear on the group's financial position and prospects — and have written that assessment down.
Is there a group risk register that is genuinely kept up to date, rather than refreshed for an occasion?
A sponsor will look at the revision history. A register last touched eighteen months ago reads worse than a thin one updated last quarter.
What discharges this
register — A current group risk register giving, for each risk, likelihood, financial impact, owner and mitigation.
The group must keep a register of its current risks and refresh it on a stated cycle, rather than assemble one when somebody asks.
When risks are identified, do the five categories all get looked at — operational, financial, strategic, regulatory and climate?
Climate is the category most often missing. It is also the one an investor's ESG screen looks for first.
What discharges this
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 identification must reach operational, financial, strategic and regulatory risk, and climate-related risk alongside them — the category the TCFD recommendations address.
Does every risk on the register name an individual owner — a person, not a department?
'Finance' is not an owner. A named individual is what makes a mitigation action chase-able.
What discharges this
register — Every risk names an accountable individual.
Every risk on the register must name the individual accountable for it.
Does each risk carry documented mitigating actions whose progress is actually monitored?
The test is monitoring, not existence. Actions with no status and no review date are a wish list.
What discharges this
register — Each risk carries mitigating actions with a status and a review date.
Every risk must carry mitigating action that is written down, and progress against that action must be tracked.
Are the risks that specifically bear on financial position and prospects flagged as such, and linked to the procedures that address them?
This is the join between the general risk register and the FPPP file. Without it, the two documents live separate lives.
What discharges this
register — Risks bearing on financial position and prospects are marked as such and each maps to the named procedure that addresses it.
Risks bearing on the company's financial position and prospects must be marked as such and tied to the procedures that address them.
High-level reporting environment
0 / 1The governance structure, the people and the control environment underneath financial reporting: board and committees, the finance function, internal control, internal and external audit.
Are there approved written terms of reference for the audit and risk, remuneration and nomination committees?
Committees that exist in practice but have no approved terms of reference do not exist for this purpose. This is Provision 14 of the UK Corporate Governance Code, which is comply-or-explain — so a company can list having explained the departure, and a sponsor will still ask why it is being explained rather than fixed. The audit committee's EXISTENCE is a different question and a harder one: see 2.2a.
What discharges this
terms of reference — Signed terms of reference for each of the three committees, stating composition, independence requirements, quorum and delegated authority.
Written terms of reference, approved by the board, must exist for the audit and risk committee and for the remuneration and nomination committees.
Forecasting and budgeting
0 / 2Whether 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.
Is the annual budget built to a written process, from the first assumptions through to the board signing it off?
ICAEW App.1 C(b) also wants the budget to reflect strategy and plans, and C(e) wants input from the people who will have to deliver it.
What discharges this
process document — Sets out the budget cycle with dates, responsibilities, the assumption-setting step, the challenge and iteration stages, and the board approval point.
The annual budget must be built under a documented process, running from the setting of assumptions through to board approval.
Does the board sign off budgets and forecasts before the period they cover starts?
Before the period starts is the whole point. A budget approved in month three of the year it governs is a record, not a plan.
What discharges this
board minutes — Board approval of the budget recorded on a date before the start of the financial period it covers.
Senior management and the board must approve the budget and the forecasts before the period they cover has begun.
Management reporting framework
0 / 1The quality, timeliness and content of the financial and operational information the board actually receives — including between reporting dates.
Has each business segment got its KPIs written down, with an agreed definition for each one?
Definition means the formula, the data source and the owner — not just the name of the metric. Non-IFRS measures disclosed at IPO have to be defined consistently and reconciled.
What discharges this
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.
The KPIs must be defined and written down for each business segment.
ESG, climate and sustainability reporting
0 / 1Procedures for identifying, managing and reporting environmental, social and governance matters — including how climate risk reaches the risk register, the forecasts and the impairment models.
Are climate-related risks — both transition and physical — formally in the group risk matrix?
Both kinds. Physical risk alone, or transition risk alone, is a partial answer and reads as one.
What discharges this
register — A risk register in which physical and transition climate risk appear as separate entries, each traceable to the assessment behind it.
Climate-related risk must sit in the group's own risk register, with physical risk and transition risk identified separately.
Significant transaction complexity
0 / 2Procedures for transactions carrying significant accounting complexity, financial exposure or risk — including related party transactions, which are where a listing goes wrong quietly.
Is there a written policy defining what counts as a significant transaction under the listing rules?
Assessing transactions case by case is the common finding, and it fails: without a defined threshold there is no way to show a transaction was correctly *not* notified.
What discharges this
policy — Defines what constitutes a significant transaction, states the class tests applied, and names who performs the assessment and when.
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.
Is the approval chain for significant transactions defined — CFO, then audit committee, then board?
The sequence matters. An audit committee that sees a transaction after the board has approved it is a review in name only.
What discharges this
process document — Sets out the approval sequence with the threshold that triggers each stage.
Significant transactions must pass a defined approval chain: review by the CFO, then by the audit committee, then approval by the board.
Strategic projects and initiatives
0 / 1Oversight of the capital projects and initiatives with material financial consequences — appraisal, monitoring, tax, and getting them into the right accounting period.
Is there a written way of approving contractors and suppliers and of judging how they perform?
ICAEW App.1 F(g) covers scoping and approving contractors and monitoring their performance — the monitoring half is the one usually missing.
What discharges this
process document — Covers approval and onboarding, and states how contractor performance is monitored against the scope and reported.
Approving contractors and suppliers, and monitoring how they perform, must follow a documented process.
Financial accounting and reporting
0 / 1Compliance with IFRS and with the external reporting obligations of a listed company — including the market abuse machinery that has to work from day one.
When a new or amended IFRS standard lands, is there a route for assessing it and telling the people affected?
ICAEW App.1 G(c) expects the impact considered on a timely basis and changes promptly communicated. A public company is expected to form its own view rather than wait for the auditor's.
What discharges this
process document — Names who monitors standard-setting, how impact is assessed, and how policy changes are communicated to the entities that must apply them.
New and amended IFRS standards must be monitored, and the policy changes that follow from them communicated, under a defined process.
IT environment
0 / 1The systems, controls and infrastructure that produce FPP information — access, segregation of duties, resilience, and the third parties the group depends on.
Are backup arrangements documented and tested by actual restore?
Tested means a restore was performed. A backup job that reports success has not been tested.
What discharges this
test record — Backup schedule and retention documented, plus a restore test record showing data was successfully recovered.
Backup arrangements must be documented, and restoring from them must have been tested.
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FPPP v1 (UKLR, 2026) · rules current as of 2026-10-30