For an FRS 102 company preparing its first accounts under the principal 2026 amendments, revenue and lease accounting deserve attention now. Future filing reforms and consultation proposals need a different response. Treating everything as equally urgent risks diverting time from the decisions that could delay the next close.
Where to focus:
- FRS 102 reporters: establish the first affected accounting period and resolve material revenue and lease questions before the close.
- Companies applying the UK Corporate Governance Code, and subsidiaries supporting their reporting: confirm the evidence needed for internal control reporting.
- Companies House filers: plan for the announced April 2028 changes, with particular attention to entities whose current filing process will need to change.
- All readers: monitor the Modernising corporate reporting proposals separately. Consultation does not change the requirements for the accounts currently being prepared.
Priority for the next close: FRS 102
The principal Periodic Review 2024 amendments to FRS 102 apply to accounting periods beginning on or after 1 January 2026, with early application permitted. The date the accounts are signed is not the test.
For a company with a 31 December year end, the year beginning 1 January 2026 is therefore within the principal new requirements. Finance teams should already be assessing the revised revenue and lease accounting requirements and the relevant transition provisions.
The difficult work often sits in the contracts. A revenue arrangement may contain several promises or variable consideration; lease terms may be held by operations rather than finance. Identify the documents and accounting decisions early enough for the team to investigate them properly.
Explain material effects to directors and lenders using the definitions in the company’s actual agreements. An accounting change does not automatically change cash flows, and a movement in a reported ratio does not by itself establish a covenant breach.
Check applicability: internal control reporting
Provision 29 of the UK Corporate Governance Code 2024 applies for financial years beginning on or after 1 January 2026 to companies within the relevant Code framework. It is not a new universal reporting requirement for private companies.
A private UK subsidiary may nevertheless receive evidence requests from a parent subject to that framework. Clarify whether a request arises from the subsidiary’s own obligations or from the parent’s reporting process, and agree the required evidence and timetable.
Plan ahead: Companies House filing
Companies House has announced accounts-filing changes from April 2028, including filing through commercial software. The announcement also covers additional filing requirements for small and micro entities, with an option to withhold specified profit and loss information from public view.
For a group, a smaller subsidiary may need a different filing process even when the main reporting system is well established. Check software coverage and responsibility for each entity, rather than assuming the group arrangement covers them all.
Filing and public disclosure are separate questions. The announced option to withhold specified profit and loss information from public view does not remove the obligation to file it.
Treat April 2028 as the announced implementation timetable and check the final requirements and transitional arrangements before changing procedures. It is not a reason to apply future filing rules to today’s submission.
Monitor: proposals to modernise corporate reporting
The government’s Modernising corporate reporting consultation, launched on 7 September 2026, is a separate workstream. A proposal is not an enacted requirement.
For now, a short watchlist is proportionate. Record which proposals could affect the organisation and who will follow their progress. There is little value in designing a detailed reporting process around a proposal whose final scope is still unsettled.
This distinction also helps boards read external briefings. “The government is consulting on” and “the company must” should never be interchangeable.
What belongs in the board update?
The board update should lead with decisions and deadlines. For each affected entity, show the first relevant period, the material accounting or disclosure effect, and any unresolved issue that could hold up reporting.
A supporting register can hold the framework, evidence required and responsible person. Keeping future implementation plans and consultation proposals separate makes it easier to see what needs management attention now.
Bring unresolved decisions to the board with a clear explanation of the consequence. For example, if missing lease data could delay the accounts, identify who can obtain it and by when. That gives directors something useful to resolve.
Position reviewed 21 October 2026. This is a dated reporting update, not an exhaustive list of obligations. Check subsequent announcements and the requirements applicable to each entity before implementation.
Sources and further guidance
FRC: FRS 102 and the Periodic Review 2024 amendments
Companies House: announced accounts-filing changes from April 2028
Government: Modernising corporate reporting consultation
FRC: Provision 29 and the auditor’s responsibilities