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In January 2026, the revised Provision 29 of the UK Corporate Governance Code 2024 became applicable. What does the new Provision mean for your corporate governance reporting, and what corporate reporting challenges does it create?

What is the UK Corporate Governance Code? 

The UK Corporate Governance Code, formerly known as the Combined Code, is published by the Financial Reporting Council. It sets out standards of good practice for listed companies, covering:

• Board composition
• Board development
• Remuneration
• Shareholder relations
• Accountability
• Audit

What is Provision 29?

The revised Provision 29 of the Code requires company’s boards to make an annual public declaration on the effectiveness of their material internal controls. 

It came into effect on 1 January 2026 and covers financial, operational and compliance controls, mandating detailed information on how the board has monitored them. It also requires a declaration of the effectiveness of these controls. 

It represents a significant operational change to the UK Corporate Governance Code, evolving compliance from simply reviewing controls to formally declaring their effectiveness. 

For those responsible for corporate reporting, Provision 29 is important in that it raises expectations around evidence, governance and reporting clarity. The internal controls declaration, marking a notable shift in the UK corporate reporting process.

What Provision 29 Actually Requires

Provision 29 requires boards to:

• Monitor the company’s risk management and internal control framework
• Conduct effectiveness reviews at least annually 
• Cover all material controls:
  • financial
  • operational
  • reporting
  • compliance

Crucially, it requires boards to disclose in the annual report:

• How the review was carried out
• A formal internal controls declaration of effectiveness
• Any material weaknesses and remediation actions

What Does Provision 29 Not Require?

We’ve looked at the additional requirements Provision 29 introduces. Equally important is to understand what it doesn’t require — to save you unnecessary work. 

• There is no requirement to list every control
• There is no prescribed number of controls
• The focus is on governance and oversight, not volume

What’s Changed in Practice (And Why It Matters)

There has been a shift in the importance accorded to board oversight of controls, moving it from a background process to a ‘front and centre’ statement.

Previously, companies had to state they had reviewed controls. Under the revised Provision 29, they must publicly stand behind the effectiveness of those controls.

This may seem a subtle shift, but — particularly set against the increasing audit and reporting pressure corporates face — it has multiple implications:

• There is greater board accountability for the controls in question
• It positions a stronger link between:
  • risk
  • controls
  • reporting narrative
• And it invites increased scrutiny from:
  • investors
  • auditors
  • regulators

As a result, Provision 29 moves internal controls from a background process to a visible aspect of the annual report story — making it a key element of UK financial reporting best practice.

Tackling the Practical Challenge: Evidence, Not Just Process 

This is precisely where most teams will feel the impact. While Provision 29 doesn’t prescribe how many controls a company should have (and therefore, a board should test/report on), or how to test them, it does expect:

• clear rationale for what is “material”
• evidence to support the board’s declaration

What does this mean in practice for UK listed companies’ reporting requirements? Companies will need to evidence:

• stronger documentation
• clearer audit trails
• alignment across finance, risk, and governance

The challenge here isn’t defining controls; it’s about proving they work, consistently and credibly.

Common Misconceptions About Provision 29

When it comes to Provision 29, it’s worth clarifying some requirements that can often be misunderstood:

Myth: We need to document every control
Truth: The focus is on material controls, not completeness

Myth: We need to disclose detailed testing
Truth: There is no expectation to publish granular testing

Myth: There’s a standard number of controls
Truth: It’s company-specific, based on risk

Myth: This is just a compliance exercise
Truth: It’s about governance quality and transparency

Proportionality is key here: controls should be material and specific to the business. Reporting needs to evidence the quality of governance, reported in a transparent way.

What Reporting Teams Should Be Doing Now

There are some practical, actionable steps boards and reporting teams should take to make Provision 29 compliance pain-free: 

• Define your “material controls” in good time. Ensure they’re aligned to your principal risks
• Review your current control frameworks to identify any gaps in coverage or documentation
• Align all your stakeholders: the CoSec, Finance, Risk, Internal Audit
• Test your reporting readiness: can you explain your controls clearly in narrative form?
• Plan for any impact on your reporting timeline: bake in time for additional review, validation and sign-off

Ensuring you build structured workflows to ensure smooth, timely reporting processes is vital. To this end, it’s worth considering whether bringing in external expertise can help streamline annual report production and avoid last-minute pressure.

Provision 29: A Reporting Shift, Not Just a Governance Change

Provision 29 doesn’t radically change governance frameworks. But it does change how confidently and overtly companies must stand behind them; it’s a shift from internal assurance to external accountability.

Early preparation for this shift, as you approach your next reporting season, will:

• reduce pressure
• improve clarity
• strengthen overall reporting quality

For many companies, this will be less about adding controls and more about making existing ones visible, evidenced and credible. To help prepare for this next evolution of corporate governance reporting, consider working with an external expert who can guide you through the process.

Perivan has worked with hundreds of companies to support their annual reporting. From our expert “can-do” design team to the largest 24-hour typesetting capacity in Europe, we deliver full end-to-end support.

As a member of the LSEIG Issuer Services Marketplace and listed as a trusted service provider by the Association of Investment Companies (AIC), Perivan helps clients to ensure their reporting is painless, compliant and best practice.

Perivan could help make your compliance with Provision 29 smooth, successful and stress-free. Contact us to find out more.