Consultation Responses

IR Society News Industry News Consultation Responses Policy & Positions 29 September, 2025

The amendments improve interoperability/alignment with IFRS S1 and S2 by aligning language, adopting the financial control approach for GHG boundaries and incorporating several IFRS reliefs. They also introduce practical considerations for carrying out a DMA, clarify the role of materiality as a general filter, and streamline topic lists, which should simplify the process and reduce unnecessary documentation. The proposed changes should therefore result in shorter, more decision-useful reporting by eliminating confusion and trimming boilerplate disclosures. However, more guidance is needed around the thresholds that can be used to determine which impacts are included in the sustainability statement, to avoid undue scrutiny from assurance providers.

IR Society News Industry News Consultation Responses Policy & Positions 19 September, 2025

The Society supports the introduction of UK SRS to improve comparability, clarity, credibility and global alignment/ interoperability in sustainability disclosures, underpin transparency and maintain the UK’s appeal as an investment destination. We support the 6 proposed amendments, including extending the ‘climate only’ relief for two years to benefit those who are less mature in their reporting practices, but we suggest DBT engages with investors to ascertain whether they have concerns. To promote transparency, it would be beneficial for ‘safe harbour’ provisions akin to s463 to apply in respect of forward-looking reporting requirements introduced under UK SRS, and also in respect of information that relies on third-party data or estimations. We also call for more clarity around dual compliance with overseas reporting requirements, equivalence agreements with oversees jurisdictions, and clearer mapping tools to join UK SRS with CSRD/ESRS and SEC rules. Requiring economically significant private entities to report against UK SRS would support transparency across value chains, reduce the risk of regulatory arbitrage and avoid disincentivising those companies from seeking a London listing. It would also present a valuable opportunity to simplify the various thresholds embodied within the Companies Act 2006, and eliminate the need for multiple filings in different formats.

IR Society News Industry News Consultation Responses Policy & Positions 19 September, 2025

The Society supports an initial voluntary/opt-in registration regime, with transition from voluntary to mandatory registration encouraged once there is greater maturity/number of providers/standardisation in the regulations. In our view, robust internal governance and external stewardship mean it is unlikely that issuers would use unregistered providers unless there is a very good and demonstrable reason and, in these circumstances, this should be able to be communicated to stakeholders. We also support the proposed profession-agnostic approach to provide the flexibility to accommodate the different skills required to conduct sustainability assurance. An overriding principle of the registration regime needs to be equivalence with other jurisdictions, so that issuers can use a provider that can work across its geographical footprint. In relation to any future mandatory assurance, we suggest phasing in terms of having initial ‘comply or explain’ reliefs, size thresholds (with large-cap brought in first), a phasing in of the disclosures that are subject to assurance requirements, and is introduced at a time where the market choice for assurers has matured (and there is maturity and stability of the UK SRS regime), with account taken of the experiences in the EU with mandatory assurance on sustainability reporting (CSRD/ESRS) starting from the first year of application. It is important to recognise the associated costs to businesses of collecting, reporting and assuring sustainability information, especially for more resource-constrained smaller caps, and the potential negative impacts on ‘UK plc’ competitiveness (in particular small and medium sized issuers) and attractiveness of UK listing.

IR Society News Industry News Consultation Responses Policy & Positions 17 September, 2025

The Investor Relations Society has responded to DESNZ, tentatively supporting mandated disclosure for listed entities on the basis it is phased, with an initial period of ‘comply or explain’ relief and/or size threshold phasing with FTSE100 brought in first. This is to help balance ambition with capacity, enable market expertise and best practice to develop (particularly around scenario analysis against extended timeframes) and help mitigate any potential impact on the perceived attractiveness of the UK market. We also strongly suggest a phased/delayed approach for 'economically significant' private entities, and additional reliefs/exemptions for any issuers where climate/transition are not considered a material risk or opportunity, and reiterate our stance that reporting entities should have the flexibility to choose between including transition plans in their entirety within the ARA, or separately.

IR Society News Industry News Consultation Responses Policy & Positions 10 September, 2025

The Investor Relations Society has responded to the FCA, supporting a broader definition of ‘addressable liquidity’ that could potentially make UK stocks more investable (particularly for small- and mid-caps), and supporting the FCA’s proposed establishment of a post-trade consolidated tape for equities, provided it is complete, accurate and timely.

IR Society News Industry News Consultation Responses Policy & Positions 27 June, 2025

The Investor Relations Society has responded to the ISSB, welcoming the ISSB’s approach in proposing targeted amendments to IFRS S2 to clarify the application of GHG emissions disclosure requirements, as it aims to balance the need for high-quality, decision-useful information with the practical challenges that preparers face in data collection and reporting. The Society supported these reliefs as a pragmatic and proportionate evolution of IFRS S2, whilst emphasising the importance of maintaining a strong focus on consistency and transparency, and the need for clear disclosures about the methods, assumptions, and scope of emissions reporting.

IR Society News Consultation Responses 20 June, 2025

The Investor Relations Society has responded to the LSE's discussion paper on Shaping the Future of AIM. The Society has a growing number of AIM-listed Members, and we have set out below our general, high-level comments on those aspects of most relevance to our Members. In summary, the IR Society supports the London Stock Exchange's proposals to reduce regulatory burdens and costs for AIM companies. These initiatives have the potential to foster a thriving and more dynamic market that can attract and retain growth-oriented businesses than at present.

IR Society News Industry News Consultation Responses Policy & Positions 10 June, 2025

The IR Society has responded to the Government's proposal to extend gender pay gap reporting to ethnicity and disability, calling for minimum ‘response rate’ thresholds for employee data (on ethnicity/disability) before any employer publication becomes mandatory, to reduce the risk of misleading/unreliable reporting. Measures requiring that employers seek to collect this data (on a voluntary basis) from employees may be more appropriate at this stage.

IR Society News Industry News Consultation Responses Policy & Positions 6 May, 2025

The IR Society has responded to EFRAG's questionnaire on how to simplify the ESRS as part of the 'Omnibus' proposals, principally focusing on DMAs, which are of significant benefit to stakeholder understanding but require more guidance on recommended process to aid consistency, and interoperability, which is essential but needs to be carefully thought through and managed.

IR Society News Industry News Consultation Responses Policy & Positions Blogs 19 February, 2025

The IR Society responded to the FRC consultation on the review of the Stewardship Code on behalf of our members, broadly supporting the separate principles for proxy advisers and their users, and the new reporting requirements that should provide IRs with useful intelligence on key issues for their significant investors.

IR Society News Industry News Consultation Responses 6 February, 2025

The Society's overall concern is to avoid the complexity and confusion that would result if the UK were to introduce a taxonomy to support investor decision making, stewardship and engagement without very strong alignment with the EU Taxonomy.

IR Society News Industry News Consultation Responses Policy & Positions 14 November, 2024

The Society would support a system based on the IFRS Foundation taxonomy, to promote the international consistency and comparability of annual financial statements and thus help attract international issuers, dual listings and global investors/capital. Any mandatory reporting and tagging of sustainability-related data would impact on costs, process and timetable for filing ARAs and thus should be phased in over time, starting with the largest caps, to enable the development of software solutions/best practice. Moreover, the cost of introducing ‘disclosure management systems’ to comply with any mandatory sustainability reporting would currently be very significant for small- and mid-cap companies.

IR Society News Industry News Consultation Responses Policy & Positions 25 October, 2024

The Society raises issues around the materiality timeframe and quantification/ assessment for proposed requirements for prospectuses to include climate-related disclosure, and supports the concept of introducing a safe harbour for forward looking disclosures but calls for further review of the criteria to ensure it would cover forward-looking climate-related and transition reporting.

IR Society News Industry News Consultation Responses Policy & Positions 24 October, 2024

This IR Society response supports transparency of fund investment in the UK’s ‘unlisted’ quoted SME markets (AIM and Aquis) separately from unlisted equity as this could facilitate investor targeting for AIM companies.

IR Society News Industry News Consultation Responses 15 July, 2024

This IR Society response expresses concern around the risks of requiring this non-GAAP reporting in the back half of the annual report, which would significantly increase the audit burden and would be especially difficult when the reporting timetable is tight.

IR Society News Consultation Responses 28 June, 2024

This IR Society response calls for increased standardisation, given the sizeable disparities in price and quality, rigour and methodology amongst providers.

IR Society News Consultation Responses 6 June, 2024

This IR Society response calls for simplicity to allow straightforward and speedy implementation, supports the eligibility of companies listed/traded on a UK recognised stock exchange (including investment trusts) for the UK ISA, but questions the exclusion of companies with overseas incorporations (except in the case of secondary listings).

IR Society News Consultation Responses Policy & Positions 5 June, 2024

In this IR Society response, which draws on the findings from our 2023 member poll on investment research, we emphasise the importance of research for valuations and the London markets, noting the impact of MiFID II unbundling on the quality of coverage and the industry perspectives provided. We are therefore generally supportive of the FCA's proposals for increased payment optionality as this could lead to increased/improved quality of coverage for small- and mid-caps, provided the associated ‘guardrails’ are proportionate and aligned with the equivalent US and proposed EU regimes.

IR Society News Consultation Responses Policy & Positions Research & Surveys 5 January, 2024

This IR Society response draws on the findings from recent member research on Scope 3 and SECR reporting.

IR Society News Consultation Responses Policy & Positions 5 October, 2023

This IR Society response draws on the findings from the ESG data/ratings survey carried at Easter this year among our IRO Members, which illustrate a level of dissatisfaction with the current quality of engagement between companies and ESG data and ratings agencies. We hope this principles-based Voluntary Code of Conduct that is being developed for providers of ESG data and ratings will be helpful for our members, given the amount of time/resource IR departments currently spend dealing with these agencies.