What does Coronavirus mean for corporate reporting?
The latest communications guidance and advice for companies around COVID-19.
Below is a summary of the key guidance, points of reference, and examples of how companies are responding.
Delays to corporate reporting and filing accounts
The latest joint statement from the FCA, the FRC and the PRA encourages companies to make use of the time available within regulatory deadlines to ensure accurate and carefully prepared disclosures, subject to meeting the requirements of Market Abuse Regulations.
The FCA is permitting a temporary delay in the publication of audited annual financial reports by up to two months (from four to six months from the end of the financial year) and by up to one month for half yearly financial reports if required. However, companies will still need to observe their other disclosure obligations.
The FRC's Lab has published two new reports providing practical guidance to companies in areas of reporting that investors have highlighted as being most critical for COVID-19 related disclosures. The two reports are 'Going concern, risk and viability' and 'Resources, action, the future'.
The London Stock Exchange has provided an update for market participants. To assist companies in the preparation of their annual accounts, AIM companies can apply for a three-month extension to publish their annual audited accounts. The extension is available for companies with financial year ends between 30 September 2019 and 30 June 2020.
AIM Regulation will also permit AIM companies that need extra time to prepare their half-yearly report an additional one month.
Companies can apply to Companies House for a three month extension to file their accounts, however applications must be submitted in advance of the mandatory filing deadline.
The European Securities and Markets Authority’s (ESMA) recommendations covering market disclosure and financial reporting around COVID-19.
Shortly before the 4 April deadline for private and listed companies to publish their gender pay gaps, the government announced that they have suspended gender pay gap reporting for this reporting year due to COVID-19. Companies that haven't already reported won't now have to.
Implications for AGMs
The Government has now introduced the Corporate and Insolvency Bill to put in place a series of measures to amend insolvency and company law to support businesses impacted by COVID-19. The bill includes temporarily easing burdens on businesses by enabling them to hold closed Annual General Meetings (AGMs), conduct business and communicate with members electronically, and by extending filing deadlines.
A closed AGM will allow companies to hold a meeting with the minimum number of people required (typically between two and five) by way of telephone or other equivalent means of communication.
The FRC and Department for Business, Energy and Industrial Strategy have published a Q&A designed to provide companies with additional information upon which to plan activities over the coming months.
How companies are communicating
Communication is key at this time of uncertainty. Consumer facing businesses are generally using their websites and social media to convey key messages and advice for customers and provide latest status information.
Alongside this, there are a number of additional ways in which companies can keep stakeholders informed, up-to-date and reassured:
Regulatory News Service (RNS)
The RNS is an essential tool to update the market with important information. For example, Foxtons provided a detailed breakdown of management actions in response to COVID-19 to minimise the impact on cash flow in its Q1 trading update, Glencore used the RNS to outline the impact of COVID-19 on its operations across different geographies and a huge number of companies, including Antofagasta, are having to notify the market of changes to AGM arrangements.
In line with current FRC guidance, it’s important for companies to include comprehensive emerging risk, viability and going concern disclosures on COVID-19. As one of the first December year-end reporters, HSBC is a good example of this, while DFS Furniture dedicated a significant section in its interim results to discuss the potential impact of COVID-19, considering the operational impact from both Chinese and non-Chinese suppliers as well as consumer behaviour.
With the option of face-to-face meeting all but gone, companies are relying on video and webcasts to convey key messages that require a more personal approach. For example, British Airways CEO sent a video message to staff concerning the implications.
Direct communications from leadership to customers
Companies are increasingly opting to communicate directly with customers to provide clarity and reassurance on their position, and also empower consumers to be part of a solution. For example, many supermarkets (such as Sainsburys’ CEO Mike Coupe) have been messaging customers every other day with the latest information and plans to ensure continued access to food and delivery services.
Additional resources for companies
PwC have a COVID-19 hub with a number of downloads and podcasts on business impacts, business continuity and scenario planning.
ICAEW has a useful hub that contains a range of guidance for preparers of financial statements, including information on audit and business interruption.
Useful information for preparers of financial statements.
The situation with Coronavirus remains fluid and continues to change on an almost constant basis. At Emperor, we are continually monitoring the latest guidance and best practice and will update our website with information that we feel will be helpful to our clients and partners around reporting and wider corporate communications, as and when it arises. If we can support you in any way during this difficult period, please get in touch at [email protected].
This article was updated on 17 June 2020 to reflect changing best practice advice.