The 73 FPPP criteria
Nine areas, each mapped to the UK Listing Rules and to the illustrative objectives in ICAEW TECH 14/14CFF Appendix 1. Gate items are the ones a sponsor cannot give the FPPP opinion without.
FPPP v1 (UKLR, 2026) · rules current as of 2026-09-11
Group level, or every entity
13 of the 73 criteria have to hold at every entity inside the IPO perimeter, not at the holding company alone; the other 60 are satisfied once, at the top. That distinction is the multiplier nobody budgets for — one policy is one piece of work, and the same policy adopted at eleven subsidiaries is eleven board meetings. It is also why readiness for one of these is the group's weakest entity rather than its average.
Directors' risk assessment of FPP
ICAEW §A · 9 criteriaWhether the directors can identify and manage the risks that bear on the group's financial position and prospects — and have written that assessment down.
Risk management framework
Compliance & RiskA formal Risk Management Framework must be documented, describing the overall approach to identifying, assessing, and mitigating risk.
What discharges it
framework document — Sets out how risks are identified, assessed, owned, mitigated and escalated, and on what cycle the process itself is reviewed.board approved
Group risk register
In free scanCompliance & RiskA Group Risk Matrix must exist and be updated periodically to reflect current risks.
What discharges it
register — A current group risk register giving, for each risk, likelihood, financial impact, owner and mitigation.no older than 6 months
Risk categories covered
In free scanCompliance & RiskRisk identification process must cover: operational, financial, strategic, regulatory, and climate-related (TCFD - Task Force on Climate-related Financial Disclosures) risks.
What discharges it
register — Each of the five categories is represented by at least one identified risk, and the register shows which category each risk belongs to.
Risk assessment methodology
Compliance & RiskA risk assessment methodology must be documented — showing how likelihood and financial impact of each risk is assessed.
What discharges it
process document — Defines the likelihood and financial-impact scales, the thresholds between them, and how a combined rating is derived.
Risk owners
In free scanCompliance & RiskRisk owners must be formally assigned for each identified risk.
What discharges it
register — Every risk names an accountable individual.named owner
Mitigation actions
In free scanCompliance & RiskMitigation actions must be developed, documented, and monitored for each risk.
What discharges it
register — Each risk carries mitigating actions with a status and a review date.operated if triggered
Board and committee challenge
Compliance & RiskThe Board and Audit & Risk Committee must have a formal process for reviewing and challenging the risk management process.
What discharges it
committee minutes — Minutes record the committee reviewing the risk register and challenging management on it — not merely receiving it.no older than 12 months
FPP-relevant risk factors
In free scanCompliance & RiskRisk factors specifically relevant to financial position and prospects must be identified and linked to FPP procedures.
What discharges it
register — Risks bearing on financial position and prospects are marked as such and each maps to the named procedure that addresses it.
Directors' FPPP risk assessment
GateBoard / Company SecretaryThe directors' risk assessment must explicitly identify, assess, and consider risks relating to each of the following seven areas: (i) high-level reporting environment, (ii) forecasting and budgeting, (iii) management reporting framework, (iv) significant transaction complexity and potential financial exposure or risk, (v) strategic projects and initiatives, (vi) financial accounting and reporting, and (vii) the IT environment — and document how FPP procedures address those risks.
What discharges it
framework document — A single directors' FPPP risk assessment addressing each of the seven areas by name, and stating for each the procedures relied upon.board approved
High-level reporting environment
ICAEW §B · 12 criteriaThe governance structure, the people and the control environment underneath financial reporting: board and committees, the finance function, internal control, internal and external audit.
Board skills matrix
Board / Company SecretaryBoard composition must include members with relevant financial and industry-specific skills — documented in a Board Skills Matrix.
What discharges it
matrix — Maps each director against financial and sector-specific skills, and identifies the gaps the nomination committee is recruiting against.
Audit committee body
GateBoard / Company SecretaryA body must be responsible for performing the audit committee functions required by DTR 7.1.3R: monitoring the financial reporting process, the effectiveness of the internal control and risk management systems, and the statutory audit of the annual and consolidated financial statements.
What discharges it
board minutes — The board resolution establishing the body and delegating the DTR 7.1.3R functions to it, together with the disclosure naming the body and its members required by DTR 7.1.5R.board approved
Committee terms of reference
In free scanBoard / Company SecretaryFormal written Terms of Reference must be in place for: Audit & Risk Committee, Remuneration and Nomination Committees.
What discharges it
terms of reference — Signed terms of reference for each of the three committees, stating composition, independence requirements, quorum and delegated authority.board approved
ICFR framework
GateEvery entityCompliance & RiskA documented Internal Control over Financial Reporting (ICFR) framework must exist.
What discharges it
framework document — Identifies the key financial reporting controls, names a control owner for each, and states how design and operating effectiveness are assessed and on what cycle.
Delegation of authority
Every entityCFO / FinanceA Delegation of Authority (DoA) matrix must be in place showing approval limits for procurement, payments, and commitments — embedded in financial systems.
What discharges it
matrix — Approval limits for procurement, payments and commitments, by role and value band, stating for each how the limit is applied — enforced in the system, or by a named compensating control where the system cannot carry it.board approved · must have operated: Either system configuration or a workflow export showing the limits enforced, or a sample of recent approvals at and above each threshold showing the matrix was the one actually followed.
Finance function resourcing
CFO / FinanceThe finance function must be adequately staffed with qualified personnel, evidenced by a documented organisational chart covering roles, reporting lines, and responsibilities from the CFO to key accounting staff.
What discharges it
org chart — Roles, reporting lines and responsibilities from the CFO to key accounting staff, with qualifications shown and vacancies marked.
Whistleblowing policy
Every entityCompliance & RiskA whistleblowing policy and escalation procedure must be formally documented and communicated to all staff.
What discharges it
policy — Names the reporting channel, protects the reporter from retaliation, and states how reports are escalated, investigated and tracked to conclusion.board approved · must have operated: Evidence of communication to staff — intranet posting, induction pack or training record.
Control deficiency remediation
Compliance & RiskA process for identifying, reporting, and remediating internal control deficiencies must be in place and documented.
What discharges it
process document — States how deficiencies are logged, rated for severity, communicated, assigned and cleared, with timescales and an escalation threshold to the audit committee.
Internal audit
Internal AuditAn internal audit function must exist — or its absence must be formally explained with compensating controls documented.
What discharges it
terms of reference — An internal audit charter and annual plan approved by the audit committee — or, where there is no function, a board-approved explanation naming the compensating controls relied upon.board approved
External audit recommendations
CFO / FinanceA process for handling and implementing recommendations from external auditors must be documented.
What discharges it
process document — States how management-letter points are assigned, tracked and reported to the audit committee, with the current status of open points available.
Accounting records
Every entityCFO / FinanceAccounting records must be maintained up to date and capable of producing timely management information.
What discharges it
management accounts — Records support production of management information within the stated close timetable.must have operated: For the most recent closed month: the trial balance, and the key balance-sheet reconciliations, showing they were completed and reviewed.
Statutory-to-management reconciliation
CFO / FinanceA process for reconciling the statutory financial position with management accounts must be formally documented.
What discharges it
process document — A documented reconciliation between the management accounts and the statutory IFRS position, with the bridge for the most recent period retained and explained.
Forecasting and budgeting
ICAEW §C · 8 criteriaWhether the group can forecast well enough to manage market expectations and support a working capital statement — the one area where the evidence is a model, not a document.
Annual budgeting process
In free scanCFO / FinanceA documented annual budgeting process must exist — from assumption-setting through to final Board approval.
What discharges it
process document — Sets out the budget cycle with dates, responsibilities, the assumption-setting step, the challenge and iteration stages, and the board approval point.
Controlled financial model
GateCFO / FinanceA financial model must exist with clearly documented logic, assumptions, and version control.
What discharges it
financial model — A single controlled master version, with an assumptions sheet, a change log, and the model's logic documented well enough for a reviewer to follow a number from driver to output.named owner
Re-forecasting
CFO / FinanceA re-forecasting process must be in place that responds to actual performance and changing business conditions.
What discharges it
process document — States the re-forecast cadence and the triggers for an out-of-cycle re-forecast, and shows how actuals feed back into the model.must have operated: The two most recent re-forecasts and what changed between them.
Sensitivity and scenario analysis
CFO / FinanceSensitivity and scenario analysis procedures must be documented, covering key business drivers (e.g. input costs, exchange rates, volumes).
What discharges it
financial model — Downside and upside scenarios run on the declared key drivers, with the mechanics visible in the model rather than pasted in as values.
Variance analysis
CFO / FinanceA variance analysis process must exist: actual results vs budget vs forecast, with management commentary reviewed by the Board on a timely basis.
What discharges it
report pack — Actual against budget and against forecast, with written explanation of material variances in both directions, in a pack the board demonstrably received.no older than 3 months
Board approval of the budget
In free scanCFO / FinanceBudgets and forecasts must be formally reviewed and approved by senior management and the Board before the start of each financial period.
What discharges it
board minutes — Board approval of the budget recorded on a date before the start of the financial period it covers.board approved
Analyst forecasts and market expectations
Investor RelationsA process for monitoring analyst forecasts and managing market expectations must be formally documented.
What discharges it
process document — Names who tracks consensus, how the company's own forecast is compared against it, and the threshold at which a trading update or announcement is considered.
Replanning on forecast
StrategyA process for updating plans and reallocating resources based on forecast monitoring must exist.
What discharges it
process document — A documented process for acting on forecast monitoring: what triggers a replan, who decides, and how a reallocation of resource is recorded.operated if triggered
Management reporting framework
ICAEW §D · 6 criteriaThe quality, timeliness and content of the financial and operational information the board actually receives — including between reporting dates.
Monthly management accounts
GateEvery entityCFO / FinanceA monthly management accounts pack must be produced covering: P&L, cash flow, balance sheet, working capital, KPIs, and divisional performance reports for each subsidiary.
What discharges it
management accounts — A monthly pack containing all six elements, with divisional reporting for every entity in the IPO perimeter.per entity
Reporting timetable
CFO / FinanceThe management accounts pack must be produced to a defined timetable — consistently and on time.
What discharges it
process document — A published close calendar, plus the actual issue date of each of the last six packs against it.must have operated: Issue dates for the last six periods, showing whether the calendar was met.
Segment KPIs
In free scanStrategyKPIs must be formally defined and documented for each business segment.
What discharges it
process document — For each segment, each KPI with its formula, data source and owner — and, for any non-IFRS measure, the reconciliation to the nearest IFRS measure.named owner
Out-of-cycle escalation
Every entityCFO / FinanceAn escalation procedure must exist for material financial events that occur outside the regular monthly reporting cycle.
What discharges it
process document — States the materiality threshold, the escalation route to the board, and the timescale — with the link to the inside-information assessment made explicit.
Management-to-IFRS reconciliation
CFO / FinanceA reconciliation process between management accounts and statutory IFRS accounts must be documented.
What discharges it
process document — The documented reconciliation with the most recent bridge retained, showing each reconciling item and who reviewed it.
Board information between dates
Board / Company SecretaryThe Board must receive timely information between periodic reporting dates about any events with a material financial impact.
What discharges it
board minutes — A documented route by which a material financial event reaches the board between scheduled reporting dates — the trigger, the threshold, and who is responsible for raising it.operated if triggered
ESG, climate and sustainability reporting
ICAEW §A · 9 criteriaProcedures for identifying, managing and reporting environmental, social and governance matters — including how climate risk reaches the risk register, the forecasts and the impairment models.
ESG oversight mandate
ESGBoard-level or committee-level oversight of ESG matters must be formally established — with documented mandate.
What discharges it
terms of reference — Board or committee terms of reference that assign ESG oversight explicitly, with minutes showing the body has exercised it.board approved
Environmental policy
Every entityESGAn environmental management policy must be documented and approved by the Board.
What discharges it
policy — An environmental policy carrying board approval, with evidence of its implementation at each entity across the group.board approved · per entity
Health and safety policy
Every entityESGA health and safety policy must be documented and implemented across all subsidiaries.
What discharges it
policy — Sustainability and health-and-safety policies or procedures, where applicable to the operations, with evidence of implementation across the material ones.
Business ethics and anti-corruption
Every entityCompliance & RiskA business ethics and anti-corruption policy must be in place and formally adopted.
What discharges it
policy — A code of ethics, anti-corruption policies and whistleblowing procedures, each formally approved at every entity in the IPO perimeter.board approved · per entity
Climate risk in the risk matrix
In free scanESGClimate-related risks — transition and physical — must be formally integrated into the Group Risk Matrix.
What discharges it
register — An ESG risk matrix in which physical and transition climate risks are each separately identified, with the supporting climate risk assessment referenced.
ESG in forecasts and impairment
CFO / FinanceESG and climate factors must be incorporated into financial forecasts, asset impairment reviews, and the valuation of provisions.
What discharges it
financial model — Financial forecasts and impairment models in which the material ESG and climate assumptions are visible and separately stated.
Climate disclosure data
ESGA process for gathering TCFD-aligned disclosure data must be in place, with defined data owners (TCFD = Task Force on Climate-related Financial Disclosures, Global Framework).
What discharges it
process document — Documented ESG data-collection procedures, a named data owner per metric, the reporting templates in use, and the review controls that apply to them.named owner
Corporate governance statement
Board / Company SecretaryA corporate governance statement must be prepared for the directors' report, including a description of internal control/risk management systems for financial reporting and a diversity policy (or explanation if none exists).
What discharges it
process document — A draft corporate governance statement in which each applicable DTR and UK Corporate Governance Code requirement is addressed, and readable against them.
Sustainability reporting process
ESGA documented process must exist for preparing the sustainability section of the Annual Report, ensuring compliance with the UK Corporate Governance Code and other applicable ESG-related regulations (including TCFD-aligned disclosures).
What discharges it
process document — A documented sustainability reporting procedure covering the reporting calendar, the responsibilities, the approval controls, and where the supporting evidence is held.
Significant transaction complexity
ICAEW §E · 6 criteriaProcedures for transactions carrying significant accounting complexity, financial exposure or risk — including related party transactions, which are where a listing goes wrong quietly.
Significant transaction policy
In free scanLegalA formal written policy for identifying significant transactions must exist — defining what constitutes a significant transaction under UKLR rules.
What discharges it
policy — Defines what constitutes a significant transaction, states the class tests applied, and names who performs the assessment and when.board approved
Accounting and tax on complex deals
CFO / FinanceA process for assessing the accounting and tax implications of complex transactions must be documented (M&A - Mergers & Acquisitions, disposals, joint ventures, financial instruments, related-party transactions).
What discharges it
process document — States who assesses accounting and tax implications, at what point in the transaction, and how the assessment reaches the board before commitment.
External advisor engagement
StrategyA process for engaging and managing external advisors for complex matters must be documented.
What discharges it
process document — Covers selection, scoping and approval of advisors, and states who is accountable for considering and acting on the advice received.
Transaction approval chain
In free scanCFO / FinanceA formal approval process must exist: CFO review → Audit Committee review → Board approval, for significant transactions.
What discharges it
process document — Sets out the approval sequence with the threshold that triggers each stage.operated if triggered
Related-party transactions
Every entityLegalRelated-party transaction procedures must be documented — covering identification, assessment, approval, and disclosure.
What discharges it
register — A maintained related-party register plus the documented procedure covering identification, assessment against the threshold, approval, and disclosure.no older than 6 months
Listing-rule compliance monitoring
LegalCompliance monitoring with UKLR (UK Listing Rules) significant transaction rules must be in place, with exceptions reported to the Board.
What discharges it
process document — Names who monitors compliance, on what cycle, and how exceptions are reported to the board.named owner
Strategic projects and initiatives
ICAEW §F · 8 criteriaOversight of the capital projects and initiatives with material financial consequences — appraisal, monitoring, tax, and getting them into the right accounting period.
Investment appraisal
StrategyAn investment appraisal process must exist for major capital projects — covering strategic fit, financial viability, risk assessment, and Board approval.
What discharges it
process document — Requires strategic fit, financial viability and risk assessment in every proposal, and names the approval threshold at which the board decides.board approved
Project management framework
StrategyA project management framework must be in place with defined milestones, budgets, timelines, and responsible owners.
What discharges it
framework document — Defines milestones, budget control, timelines and a named owner per project, with the route by which project reporting reaches the board.named owner
CapEx reporting
CFO / FinanceCapital expenditure reporting must track actual spend and commitments against approved budgets — reported to the Board regularly.
What discharges it
report pack — CapEx reporting showing actual spend AND outstanding commitments against approved budget, in a pack the board received.no older than 3 months
Contractor monitoring
In free scanStrategyA contractor and supplier approval and performance monitoring process must be documented.
What discharges it
process document — Covers approval and onboarding, and states how contractor performance is monitored against the scope and reported.
Asset economic lives
CFO / FinanceA process for measuring and formally assessing the economic lives of assets must exist (major operating assets and infrastructure).
What discharges it
process document — States how economic lives are set and reviewed, and documents the basis for asset replacement decisions.
Project tax assessment
CFO / FinanceTax implications of strategic projects must be formally assessed and documented before commitment.
What discharges it
process document — Requires a documented tax assessment before commitment, and names who performs and reviews it.
Project period cut-off
CFO / FinanceA process must exist to ensure strategic project transactions are recorded in the correct accounting period.
What discharges it
process document — Sets out the cut-off procedure for project accruals, capitalisation and commitments, and who verifies it at each close.
Project reporting up to date
StrategyA process of reporting of strategic projects must be maintained up to date.
What discharges it
report pack — The most recent project report, dated, showing status against milestones and budget.no older than 3 months
Financial accounting and reporting
ICAEW §G · 7 criteriaCompliance with IFRS and with the external reporting obligations of a listed company — including the market abuse machinery that has to work from day one.
IFRS accounting policies
GateEvery entityCFO / FinanceIFRS-compliant accounting policies must be formally documented, Board-approved, and applied consistently across all group entities.
What discharges it
policy — A group IFRS accounting policy manual, board-approved, with evidence it is the manual each perimeter entity actually applies.board approved · per entity
Standards monitoring
In free scanCFO / FinanceA process for monitoring new or updated IFRS standards and communicating policy changes must be in place.
What discharges it
process document — Names who monitors standard-setting, how impact is assessed, and how policy changes are communicated to the entities that must apply them.named owner
Key judgements and estimates
CFO / FinanceKey areas of judgement and estimation uncertainty must be identified and documented (asset lives, impairment, provisions, revenue recognition, leases).
What discharges it
process document — A schedule of key judgements and estimates with, for each, the assumption used, the basis for it, and who approved it.
Reporting timetable and deadlines
CFO / FinanceA timetable and process for preparing half-year and annual financial statements must be documented with roles assigned, meeting statutory deadlines.
What discharges it
process document — A reporting calendar working back from the DTR deadlines, with each step owned by a named individual and the review and approval gates marked.named owner
Disclosure committee
Board / Company SecretaryA finance team, Disclosure Committee, and Audit Committee must be established with documented terms of reference and clear decision-making authority.
What discharges it
terms of reference — Terms of reference for the disclosure committee, stating membership, quorum, decision-making authority, and how a candidate item of inside information reaches it.board approved
MAR and inside information
GateLegalMAR (Market Abuse Regulation) compliance procedures must be in place: insider lists maintained and updated; PDMR (Person Discharging Managerial Responsibilities) notification process; process for identifying and disclosing inside information to the market, including holding announcements where needed.
What discharges it
register — A maintained insider list, plus documented procedures for PDMR notifications and for assessing, escalating and disclosing inside information — including when to issue a holding announcement.named owner
External reporting ownership
Investor RelationsExternal reporting responsibilities must be formally assigned to named individuals, with deadlines monitored.
What discharges it
process document — Each external reporting obligation mapped to a named individual with its deadline, and a record of how compliance is monitored and delays investigated.named owner
IT environment
ICAEW §H · 8 criteriaThe systems, controls and infrastructure that produce FPP information — access, segregation of duties, resilience, and the third parties the group depends on.
Cybersecurity policy
ITA cybersecurity policy and framework must be documented, implemented, and reviewed regularly.
What discharges it
policy — A cybersecurity policy with a stated review cycle and evidence of the most recent review.board approved · no older than 12 months
Logical access controls
Every entityITLogical access controls must be in place for all key financial applications — restricting access to authorised users only.
What discharges it
system config — A current user access list for each key financial application, showing access restricted to authorised users, with joiners and leavers reflected.per entity
Segregation of duties
Every entityITUser permissions must be formally set up with appropriate segregation of duties — documented and reviewed periodically.
What discharges it
system config — A documented segregation-of-duties matrix, and a periodic access review that has actually been performed — with its outcome recorded, whether or not it raised anything.no older than 6 months · operated if triggered
Disaster recovery plan
ITA documented disaster recovery plan must exist, covering all systems critical to financial reporting.
What discharges it
process document — A disaster recovery plan naming every system critical to financial reporting, with recovery objectives, and evidence it has been approved and communicated.
Disaster recovery testing
ITDisaster recovery plans must be tested periodically, with results documented and issues addressed.
What discharges it
test record — The most recent DR test record, with results, issues raised, and evidence those issues were addressed.no older than 12 months
Backup and restore
In free scanITSystem backup arrangements must be formally documented and tested.
What discharges it
test record — Backup schedule and retention documented, plus a restore test record showing data was successfully recovered.no older than 12 months
Third-party IT providers
ITThird-party IT service providers and cloud providers must be formally contracted, assessed, and monitored with defined performance standards.
What discharges it
contract — Signed contracts with the material IT and cloud providers, with service levels defined, plus the risk assessment covering data integrity and governance and evidence of performance monitoring.
Core financial systems documented
ITCore financial systems (e.g. ERP - Enterprise Resource Planning, consolidation tools) must be formally reviewed, and key IT processes supporting financial reporting must be fully documented — covering data inputs, system outputs, and interfaces between systems.
What discharges it
process document — A system landscape document naming the core financial systems, their data inputs and outputs, and every interface between them — flagging which are automated and which are manual.
This is a readiness and gap assessment, prepared as a management tool. It is NOT an assurance opinion, NOT the reporting accountant's private FPPP comfort letter, NOT legal, tax or investment advice, and it does not make any company eligible to list or guarantee any outcome. The sponsor's opinion under UKLR 24.3.2R(5) can be given only by a sponsor, and the FPPP assurance opinion only by an appointed reporting accountant; nothing here substitutes for either. Rule citations are current as of the date shown and the UK listing regime changes — verify against the FCA Handbook before relying on any citation. Evidence tests for areas 1–4 and 6–9 are our considered interpretation of the ICAEW objectives, not an official checklist.