ACCA comments on FRC exposure draft- Guidance on the Strategic Report: Non-financial reporting

Draft amendments to Guidance on the Strategic Report: Non-financial reporting Exposure Draft issued for comment by the Financial Reporting Council in August 2017

ACCA welcomes the opportunity to provide views in response to the FRC's draft amendments on the Guidance to the Strategic Report ('the Guidance’). This response reflects the views and experience of the members of ACCA's Global Forums for Sustainability and for Corporate Reporting.

We agree with the FRC's view that the strategic report should continue to provide a cohesive narrative, subject to an entity-specific assessment of materiality. We also welcome the timely emphasis placed on directors' duty under section 172 of Companies Act 2006 ('the Act'). We’re pleased to see further amendments to the Guidance to reflect innovations in corporate reporting practice, notably encouraging companies to consider value generation more broadly.

The changes to Section 7 of the Guidance (Content Elements) are extensive, and it has sometimes been difficult to assess the overall effect of the amendments without a comprehensive comparison with the current Guidance. Our comments attached are based primarily on a review of the Exposure Draft of the revised Guidance as a standalone document.