Policy & Positions

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 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 Policy & Positions Members' News 27 February, 2025

As the market and technology evolves and investor demographics and expectations change, the Best Practice Committee refines these guidelines so that they continue to be an ongoing tool to help Investor Relations Officers tackle new challenges and improve their current skills.

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 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 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.

IR Society News Consultation Responses Policy & Positions Research & Surveys 13 September, 2023

In this IR Society response, which draws on the findings from recent member research on the FRC's proposals of most relevance to IROs, the Society is generally supportive of the proposed reforms, but calls for more flexibility and less prescription in certain areas, for example, audit committee oversight of narrative and sustainability reporting given many corporates already have a sustainability committee. The Society expresses support for increased transparency around malus and clawback arrangements, although calls for more clarity around disclosure of their ‘usage’. The Society also identifies several areas where more detailed guidance would be helpful, including ‘good’ outcome reporting, ‘significant’ appointments for ‘over-boarding’ disclosures, audit committee engagement with shareholders and oversight of narrative/sustainability reporting.

IR Society News Consultation Responses Policy & Positions 30 June, 2023

In this IR Society response, which draws on the findings from recent IRO member research on the FCA's proposed changes to the Listing Rules and on current levels of investment research in the UK, the Society was generally supportive of the proposed reforms given most IRO respondents thought the FCA proposals would reduce regulatory barriers for companies and bolster UK competitiveness. However, the Society highlights concern that a lack of shareholder approvals for major transactions could lead to significant legal and advisory costs in the early days, until a more streamlined approach based on successful transactions establishes best practice, and that a generous transition period could be needed for current standard listings to allow them to comply with the more onerous ‘single category’ continuing obligations. The Society also mentions that liquidity, depth of markets, and comparable peers are thought of by IRO respondents as the most important factors in deciding where to list the proposals, with regulation and valuations also seen as significant factors. The response also highlights some more significant issues that the Society believes may also influence the attractiveness and competitiveness of the London markets, including the UK market’s sensitivity to Directors' remuneration and compensation structures, the quality and timeliness of Investment Research, the need to encourage funds flow into UK asset managers, the suggestion of establishing a framework that better enables companies to identify all short-sellers so that they can engage with them (if they wish), and the UK’s overlapping disclosure and filing obligations which could benefit from being streamlined and simplified.

IR Society News Consultation Responses Policy & Positions 30 June, 2023

In this IR Society response, which draws on the findings from recent IRO member research on ESG data and ratings, which underline the importance of ESG ratings to corporates, illustrate a level of dissatisfaction with the quality of engagement between companies and ratings agencies, and indicate strong support for their regulation (90% of respondent IROs think they should be regulated by the FCA). The response also: • recommends that the UK regime is based on recommendations from IOSCO, to avoid regulatory arbitrage across jurisdictions; • calls for consistency and harmonisation with overseas equivalent regulations eg the EU’s recently published Proposal for regulating ESG ratings providers; and • recommends an appropriate transitional period, a phased approach so that smaller agencies have a longer transition period and an ongoing initial ‘start up’ period for new providers.

IR Society News Consultation Responses Policy & Positions 24 April, 2023

The IR Society response to this call for evidence indicates that it will be conducting some further member research on current levels of coverage, and also refers to our 2021 MIFID II survey that illustrated the impact on sell-side coverage and quality, the reduced role of corporate broking services and the significant increase in direct interaction between IR departments and investors which has ensued.

IR Society News Consultation Responses Policy & Positions 28 February, 2023

The IR Society response supports the proposals but calls for more flexibility in the way transition plans are published so that companies are permitted to include them in their annual report or other relevant reports (eg sustainability or climate reports), instead of being required to publish them as standalone reports.