The attractiveness of the UK’s public markets is an issue that is rightly framed within broader discussions around economic growth.

When UK companies float on the London Stock Exchange, they usually remain headquartered domestically; paying taxes that fund public services; offering pension savers and retail investors a share in national prosperity; and supporting skilled jobs and growth in every postcode.

Our new report argues that the public company disclosure regime has implications for the UK’s growth aspirations; and its simplification is central to boosting the UK’s appeal as a destination for companies to publicly list their shares.

Reviewing the regime

Publicly listed companies are subject to an array of disclosure requirements developed by three of the UK’s key financial rule-makers: the FCA, BIST and the FRC, alongside several more. They cover areas such as market supervision, non-financial reporting and audit, and corporate governance.

These requirements serve clearly defined regulatory and policy objectives including upholding investor protection, market integrity, and governance accountability. However, too often, requirements can overlap, creating a fragmented patchwork of rules which is complex and duplicative.

Take company annual reports and accounts – which are one of the main vessels for depositing company disclosures. In 2024, the average FTSE 100 annual report had risen by 27 per cent over five years to 152,000 words; caused, in part, by new requirements being added quicker than others are removed – a phenomenon described as “the ratchet effect”. 

In the words of one publicly-traded bank we interviewed for the research: “the typical annual report and accounts is now longer than the Bayeux Tapestry, but not as interesting.”

This has real-world consequences: for companies, producing mounting volumes of disclosures saps valuable management time from growing the business. For investors, it can be difficult to identify which information is “decision-useful”.

A clarion call for connectivity

Based on our interviews with UK, EU and US banks, traded companies, investors, corporate brokers, auditors, and many other stakeholders, a consistent message emerged. 

The primary issue is not any one rule in particular, rather it is the accumulation of regulations deriving from different supervisory regimes. 

Respondents expressed their desire for future reforms to fulfil this guiding principle: 

“Wherever possible: One issue. One rule. One disclosure requirement. One lead regulator.”

Reforming the regime

Our report’s 10 recommendations outline a vision for a more simplified disclosure regime, not simply deregulation for its own sake. They cover: 

• Short-term actions: Simplify and modernise the existing framework. 
• Medium-term actions: Build a more integrated and interoperable disclosure regime. 
• Longer-term actions: Move from volume to value. 

The proposals anticipate upcoming regulatory initiatives including the FCA’s review of the Disclosure Transparency Rules (DTR). They also reflect a number of the proposals contained in BIST’s recently announced Modernising Corporate Reporting review (MCR) which was launched just as the report went to press. 

Collaboration has been fundamental in shaping this research with contributions from colleagues and members across UK Finance Capital Markets and Wholesale, Prudential, Reporting and Tax, Sustainability, Payments and Innovation, and International streams.

With the MCR reforms currently underway and the DTR review due for release soon, we look forward to continuing to engage with the government and FCA on their proposed changes to the UK’s disclosure regime.