The Reporting on Payment Practices and Performance Regulations 2017

The Government introduced regulations1 which require large UK companies and LLPs to publish a report on their payment practices, policies and performance for financial years beginning on or after 06 April 2017.

For businesses whose financial year began in the first quarter of 2018 the deadline to publish their first report under the Regulations is imminent. We have included a table of example reporting deadlines below to help you identify the first date by which your business will be required to publish a report.

The Government has published practical guidance for companies and LLPs who must comply with this reporting duty.

Is that it?

No. If a company or LLP (and its subsidiaries) has an annual turnover of £36m or more, you may be subject to the obligation to publish an annual modern slavery statement. M

And, under new corporate governance regulations applicable to the annual reports for financial years beginning on or after 01 January 2019 large companies have to publish (as applicable) one or more of::

• the ratio of the CEO’s total remuneration to the median (50th), 25th and 75th percentile of the full-time equivalent remuneration of the company’s UK employees
• disclosure on how share price growth affects executive remuneration
• a summary of how directors have engaged with their employees
• a statement of which corporate governance code (if any) they have applied, how they have applied it and an explanation of any non-adherence to the code, and
• a new statement describing how directors complied with their duty to promote the success of the company.

The tests vary: some are on an individual basis, others on a group basis, some by reference to UK employees and others by reference to global employees. See our publication for more information on the new corporate governance regulations.

We are currently preparing guidance on how these regulations apply to financial services businesses specifically and this will be available soon.

Is help available?

Yes. We can review your group structure and help you identify which reporting regulations apply to which entities in your group.

Forewarned is forearmed.

1 The Reporting on Payment Practices and Performance Regulations 2017 (SI 2017/395) and the Limited Liability Partnerships (Reporting on Payment Practices and Performance) Regulations 2017 (SI 2017/425)