Planning for the 2021/22 reporting season - Practical help for preparers
This guide was drawn up primarily with preparers of larger private and smaller listed company accounts in mind, although others may find the guidance useful. We also signpost to more detailed guidance throughout.
In this guide the Financial Reporting Faculty looks at what is different about the current reporting season and where to focus your efforts.
This ICAEW Know-How article was created by the Financial Reporting Faculty.
Challenging times continue
Uncertainty is set to continue on from the particularly challenging year of 2020, as the ongoing experience of trading during a pandemic persists. Although businesses have experienced one reporting period mid-pandemic, they still need to explain any material uncertainties that cast doubt on an entity’s ability to continue as a going concern.
The UK left the EU on 31 January 2020 but entered a transition period which ended on 31 December 2020. As we enter this post-Brexit era, trading relationships have changed and negotiations continue with some entities having to adapt the way they conduct their business. There are also certain practical implications that arise for the preparation of the annual report and accounts now that the UK is no longer in the transition period.
Below we identify areas which may require more attention than in previous years. It is not a comprehensive list and the issues companies face will as ever depend on individual facts and circumstances.
There are no new major standards applicable for 31 December 2021 year ends, but there are some important amendments to consider.
Recent amendments – COVID-19 related rent concessions
Last year there were amendments to both UK GAAP and IFRS standards for those who have been granted rent concessions as a result of the COVID-19 pandemic. Further amendments to both UK GAAP and IFRS standards, issued in 2021, extends the time period over which the practical expedient is available for use to concessions that end on 30 June 2022. More information on the amendments can be found at icaew.com/ifrs16 and icaew.com/frs102.
Recent amendments – IBOR reform (phase 2)
Phase 2 of the interest rate benchmark reform affect accounting periods on or after 1 January 2021 for both UK GAAP and IFRS reporters. These phase 2 amendments address the financial reporting issues that might arise once the interest rate benchmark is replaced as a result of IBOR reforms. More information on the amendments can be found at icaew.com/ifrs9 and icaew.com/frs102.
In the spotlight
There are some areas of financial reporting that are in particular sharp focus.
The end of the transition period brings into effect changes in company law from 1 January 2021. UK IFRS reporters are required to switch from applying IFRS as adopted by the EU to IFRS as adopted by the UK. Additionally, where UK company law previously referred to the EEA or an EU regulated market, these references have been amended to refer to the UK only. This change has the potential to impact consolidation exemptions, ineligible group status (and therefore more companies may qualify as ‘small’), dormant company status and availability of audit exemptions. Find out more at icaew.com/brexit/financial-reporting.
Going concern and viability statements
Approaching two years into pandemic life, businesses must continue to explain any material uncertainties that cast doubt on an entity’s ability to continue as a going concern. The FRC published a thematic report on viability and going concern in 2021 which found that the disclosure of inputs and assumptions used to support viability and going concern assessments often lacked sufficient qualitative and quantitative detail. You can access recent resources published by ICAEW and others (including the FRC) at icaew.com/goingconcern.
Focus remains elevated in the area of impairment testing, including indicators of both impairment and reversals of impairment (other than goodwill), as many businesses are starting to show signs of economic recovery and resumed growth. When preparing forecasts, it’s important to review the validity of the assumptions being used to ensure that they appropriately reflect future expectations,
not only in respect of COVID-19 and Brexit but also the effects of climate change. Further guidance is available in our factsheets Applying IAS 36 Impairment of Assets and FRS 102: Impairment of Assets.
Events after the reporting period
In an evolving situation it can be challenging to assess whether or not information which comes to light after the reporting date sheds more light on conditions which existed at the reporting date, and therefore whether adjustment or disclosure is required. This may be particularly important for some entities when assessing the timing of impacts associated with COVID-19, for example new government interventions to mitigate the economic impact of COVID-19. Further COVID-19 related guidance can be accessed at icaew.com/coronavirus.
Impact of climate-related matters on financial reporting
Much discussion continues on effective reporting of ESG matters within the narrative section of an annual report (see below), but there is a strong focus from investors and regulators on companies accurately reflecting the financial impact of climate-related risks and opportunities. This FRC factsheet offers guidance in this area.
The ‘front half’ of the accounts should provide context and deeper analysis of the company’s performance, position and outlook. Investors and other stakeholders are looking for meaningful and transparent disclosure on important topics.
SECR and s172 reporting requirements
Many companies will be about to embark on their second year of SECR reporting. Take a look at the FRC’s thematic review from 2021 to see where your company might benefit from improved carbon and energy reporting.
Companies have had slightly longer to get to grips with the s172(1) requirements since they were first introduced in 2019; however, there continues to be enhanced focus on improving the quality of reporting in this area and making the statement more meaningful. Further guidance can be found at icaew.com/strategicreports.
Of particular interest to investors are disclosures concerning risk. Be it emerging risks, risk appetite, risk crystallisation, mitigating risks or how a company’s risks are evolving. Three particular types of risk that may warrant enhanced disclosure this year which are:
- cyber risks: IT risks to businesses have been heightened by virtue of the shift to remote working;
- supply-chain risks: both Brexit and Covid-19 have contributed to increased risks in this area; and
- climate risks: investors continue to demand better disclosure on climate risk to businesses.
More information can be found in the FRC’s Financial Reporting Lab report “Reporting on risks, uncertainties, opportunities and scenarios” issued in September 2021. Reporting on risk is also discussed further in this article.
Climate and sustainability reporting
Currently, when the directors of a company consider climate change to be a principal risk or uncertainty facing the company, this should be disclosed in the strategic report.
From April 2022, the UK government has confirmed requirements for mandatory climate-related financial disclosure requirements for certain publicly quoted companies, large private companies and LLPs, based upon the TCFD recommendations.
These requirements are already in place for premium listed entities for accounting periods beginning on or after 1 January 2021. An overview of current climate-related reporting requirements can be found at icaew.com/nfr.
- climate-related risks, including the new disclosures required for premium listed companies; and
- judgements and estimation uncertainty in the face of the continuing economic and social impact of COVID-19
Included with their key disclosure expectations is that information in the financial statements should be consistent with that reported in the rest of the annual report and APMs are not to be given greater prominence or authority than amounts stemming from the financial statements. They also expect information that meets the disclosure objectives of the relevant accounting standard, not just the specific disclosure requirements.
The FRC have published five thematic reports in 2021 covering:
- Interim Reporting.
- Viability and Going Concern.
- Provisions, Contingent Liabilities and Contingent Assets.
- Alternative Performance Measures.
- Streamlined Energy and Carbon Reporting.
These reports are particularly helpful for companies wanting to get a better understanding of expectations, common errors, and good practice. Links to all of these reports as well as the FRC’s key matters for 2021/2022 can be found here.
Internal preparation and planning
- Finance team – make sure that the finance team is fully aware of the issues and the deadlines.
- Organisation of underlying data – being able to navigate and access (as appropriate) data is of particular importance when working remotely. There also needs to be consistency in the data used, for example for going concern reviews and impairment testing.
- Integrated reporting – there needs to be clear communication between those responsible for preparing different aspects of the annual report to ensure that there is consistency between the ‘front half’ of the annual report and the accounts.
- Auditors – keeping the auditors informed of the specific issues faced by the company and the proposed solutions should help smooth the audit process.
Help and support
ICAEW members, affiliates or members of staff in an eligible firm with member firm access may also discuss their specific situation with the Technical Advisory Service (TAS). TAS can be contacted via telephone or webchat, for more information visit Technical Advisory Services.