ACCA responded to the following consultations in May and June:

• HMRC and HM Treasury – Reporting company payments to participators - modernising the reporting framework
  The joint consultation sought views on proposals to introduce requirements to report transactions between close companies and their participators. With HMRC wanting to reduce the small business Corporation Tax (CT) gap, ACCA emphasised the disproportionality of proposals and the vast range of transactions captured. We expressed disappointment with the lack of consideration given to information HMRC already holds, alignment with HMRC Charter principles, and cost impacts on smaller businesses.

• HMRC – Business systems integration
  The call for evidence sought views on the role of business systems integration in making it easier for businesses to keep records. As detailed in our May 2025 response to HMRC on promoting electronic invoicing across UK businesses and the public sector, we reiterated the importance of bridging software. We recommended HMRC ensure that bridging software is incorporated into any future system designs.

• HMRC – Modernising and standardising company tax returns
  Subject to certain concerns being addressed, ACCA supports the transition to a standardised, fully tagged format for Corporation Tax computations. We noted the need for clarity in the processes underpinning both alterations and the blocking of submissions. ACCA also queried the introduction of an HMRC approved software list, emphasising that it must carry the same meaning for HMRC, taxpayers and agents.

• Business and Trade Committee (‘the Committee’) – UK trade with the EU
  The call for evidence assessed the current state of the UK’s economic relationship with the European Union. ACCA emphasised the importance of a pragmatic, economically focused approach that promotes business stability. We encouraged the Committee to continue dialogue on alignment of accounting standards across international markets, including the EU. ACCA also supplied feedback across skills recognition, regulatory cooperation, SME support and digital trade.

• Financial Reporting Council (FRC) – International Standard on Auditing for Less Complex Entities (ISA for LCE)
  While ACCA believes the ISA for LCE can deliver tangible benefits, we stressed that a formal consultation on its potential adoption is needed first. We reiterated key themes from joint feedback ACCA supplied with CA ANZ in 2022, namely how the ISA for LCE can promote audit quality internationally, allowing auditors to do high-quality audits focused on the circumstances of LCEs.

• Financial Reporting Council (FRC) – Re-consultation on ISA (UK) 250 (Revised) and ISA (UK) 270 (Revised)
  While generally supportive of proposals, ACCA noted concerns regarding the inconsistency between the proposed ISA 250 (UK) (March 2026) and the International Auditing and Assurance Standards Board’s (IAASB) ISA 250 (Revised), Consideration of laws and regulations in an audit of financial statements. We observed that the divergence is likely to persist for some time, as the revision of ISA 250 (Revised) is not part of IAASB’s immediate plans. 

Separately, the government has unveiled the latest tax gap estimates and released a number of new consultations – many of which are tax-related and will likely affect members and their clients. Read our separate article to find out more.

ACCA responds to a number of consultations during the year; if you have any particular feedback or case studies that would be useful for our responses, please contact us on UKPolicy@accaglobal.com.