Governance Briefing — UK Corporate Governance Code 2024 internal controls statements
The UK Financial Reporting Council’s 2024 Corporate Governance Code now requires premium-listed company boards to publish a robust internal controls declaration for financial years beginning on or after 1 January 2026.
Executive briefing: On 22 January 2024 the Financial Reporting Council (FRC) issued the revised UK Corporate Governance Code 2024. Provision 29 compels premium-listed company boards to state annually whether their risk management and internal control systems have been effective throughout the reporting period, describe the basis of that assessment, and flag remedial actions. The requirement applies to financial years beginning on or after 1 January 2026, giving boards five reporting cycles to evidence design, operation, and oversight maturity.
Key governance signals
- Board accountability. The chair must coordinate a controls declaration approved by the board, demonstrating challenge over management testing and remediation roadmaps.
- Control framework integration. The FRC expects boards to link their declaration to the principal risk assessment, audit committee reporting, and viability statements.
- Audit committee scrutiny. Audit committees must document how they monitored control effectiveness and engaged internal audit, external audit, and risk functions.
Action checklist
- Map existing control attestations (e.g., SOX 404, UK SOX pilots) against the new Provision 29 statement to identify evidence gaps.
- Refresh testing cadences so operational, financial, ESG, and digital controls feed into a single board-level view ahead of FY2026.
- Align disclosure drafts, board minutes, and remediation logs to withstand FRC lab reviews and investor stewardship challenges.
Enablement moves
- Commission readiness assessments in 2024–2025 to benchmark documentation quality, testing coverage, and cross-functional ownership.
- Upgrade governance dashboards that integrate risk appetite metrics, incident trends, and remediation burn-down charts for quarterly board packs.
- Coordinate investor relations, legal, and sustainability teams on messaging so the controls declaration aligns with broader governance disclosures.
Sources
- FRC press release — Revised UK Corporate Governance Code
- UK Corporate Governance Code 2024 (Provision 29)
Zeph Tech partners with FTSE 350 boards to road-test controls declarations, align testing evidence, and streamline disclosure workflows before FY2026 filings.