Worked example

The diagnostic, worked through on the GDR route

The same fictional issuer and the same answers as the direct-listing run, listing depositary receipts under UKLR 15 instead. Everything below was produced by the product, including the PDF and the Excel workbook.

This is a fictional issuer. No part of it describes a real company.

The answers were authored to exercise the diagnostic — in particular the dependency graph, by denying the one criterion several others declare they depend on. They are not a redacted client, an anonymised deal or a composite of either. Nothing about any company we have worked with is inferable from this page, because nothing on it came from one.

What it was told

All 73 criteria answered: 66 claimed, 5 denied, 2 unsure. A perimeter of 6 entities, group policies not adopted at all of them, and 9 months to target admission.

Listing route: Depositary receipts under UKLR 15 (GDRs)
Incorporated in the UK: no — fixed by the route (UKLR 15.1.1R(1)), so not asked
Statutory accounts: a local framework, not on PRM 4.4.12R's list
Oversees reporting and the audit: a shareholder-elected revision commission only

Answered no

1.2 Group risk register
2.3 ICFR framework gate
2.8 Internal audit
5.2 Environmental policy
8.6 MAR and inside information gate

Answered unsure

6.2 Accounting and tax on complex deals
9.3 Segregation of duties

Every other criterion was answered yes. That is the point of the example rather than a flattering shortcut: a company claiming almost everything still comes out with a page of work, because the claims collide with the handful of denials.

What the route changes

The answers are the same as on the direct-listing run, and so is every open finding — the same 26 criteria. What the route changes is what each rests on and, where the rule under a gate does not bind on this route, how that gate is scored: 1.9 and 4.1 are gates on the direct run and findings here, so 3 gates are open on this run against 5 on the direct one. The verdict does not move: 2.3, 8.1 and 8.6 are still gates on this route, because the rule under each binds here too. The rest is labelling: the route note and the company note under the executive summary, the “On your route” column in the workbook, and the label on each finding:

Of the 26 findings, 16 rest on a rule that binds on this route and 10 are market practice here.

Finding	Priority	On a direct listing	On the GDR route
2.3 ICFR framework	Blocking	Blocking	Rule on your routeStill a gate on your route: UKLR 20.2.4AR binds you.
8.1 IFRS accounting policies	Blocking	Blocking	Rule on your routeStill a gate on your route: PRM 4.4.11R–4.4.13R binds you, on our reading of the rules (your counsel decides it).
8.6 MAR and inside information	Blocking	Blocking	Rule on your routeStill a gate on your route: UK MAR Art. 17(1) binds you.
2.4 Delegation of authority	High	High	Rule on your route
2.6 Whistleblowing policy	High	High	Rule on your route · our reading
2.10 Accounting records	High	High	Market practice on your route
4.1 Monthly management accounts	High	Blocking	Market practice on your routeNot a gate on your route: UKLR 24.3.2R(5) does not bind you, so a No here is scored as a high-priority finding rather than a fail — work the market expects before admission, not a rule that stops you listing.
5.3 Health and safety policy	High	High	Rule on your route · our reading
5.4 Business ethics and anti-corruption	High	High	Rule on your route · our reading
6.5 Related-party transactions	High	High	Rule on your route · our reading
9.2 Logical access controls	High	High	Rule on your route · our reading
9.3 Segregation of duties	High	High	Rule on your route · our reading
1.2 Group risk register	High	High	Market practice on your route
4.4 Out-of-cycle escalation	High	High	Rule on your route
6.2 Accounting and tax on complex deals	High	High	Market practice on your route
1.7 Board and committee challenge	Medium	Medium	Rule on your route · our reading
5.2 Environmental policy	Medium	Medium	Rule on your route · our reading
1.6 Mitigation actions	Medium	Medium	Market practice on your route
1.9 Directors' FPPP risk assessment	Medium	Blocking	Market practice on your routeNot a gate on your route: UKLR 24.3.2R(5) does not bind you, so a No here is scored as a high-priority finding rather than a fail — work the market expects before admission, not a rule that stops you listing.
5.8 Corporate governance statement	Medium	Medium	Rule on your route
1.3 Risk categories covered	Medium	Medium	Market practice on your route
1.5 Risk owners	Medium	Medium	Market practice on your route
1.8 FPP-relevant risk factors	Medium	Medium	Market practice on your route
2.7 Control deficiency remediation	Medium	Medium	Rule on your route
5.5 Climate risk in the risk matrix	Medium	Medium	Market practice on your route
2.8 Internal audit	Low	Low	Rule on your route

GDRs or a direct listing: every difference, rule by rule →

Executive summary

Written to be pasted into the letter. 73 of 73 criteria answered.

26 of the 73 FPPP criteria are open. 3 of them are gates on your route.

These gates remain open: 2.3 ICFR framework (UKLR 20.2.4AR); 8.1 IFRS accounting policies (PRM 4.4.11R–4.4.13R); 8.6 MAR and inside information (UK MAR Art. 17(1)). Your route has no sponsor, so each is a gate because the rule beside it still applies to you. Everything else in this report is secondary to them.

On a direct listing these findings would also be gates: 1.9 Directors' FPPP risk assessment; 4.1 Monthly management accounts. The rule under each does not bind on your route, so they are scored as findings rather than gates; the work to close them is the same.

14 findings need operating history, a system change or a third party, so they set the timeline rather than the budget and cannot be compressed by spending more: 2.3 ICFR framework; 8.1 IFRS accounting policies; 2.4 Delegation of authority; 2.6 Whistleblowing policy; 2.10 Accounting records; and others. These are the items to start this month.

4 of the open findings are foundations that other criteria stand on, so sequencing is not a preference: 1.2 Group risk register alone has 7 criteria that cannot be satisfied until it is in place. Closing dependent items first means doing them twice.

9 of the findings are consequences of other open items rather than separate problems — they resolve when their root does. The number of workstreams here is 17, not 26.

8 findings need an external specialist — reporting accountant, listing counsel, tax or model review — so they carry a procurement lead time before any work starts.

13 findings must hold at every one of the 6 declared perimeter entities. Group readiness on those is the weakest entity, not the average, so partial adoption does not partially close them.

Listing route: Depositary receipts under UKLR 15 (GDRs)

No sponsor is appointed on this route, so UKLR 24.3.2R(5) — the confirmation this product is named after — does not bind you. The board's own confirmation to the FCA (UKLR 20.2.4AR) and UK MAR's inside-information duty, applied by UKLR 15.3.1R(4), do.

Of the 73 criteria asked here, 35 rest on a rule that binds on your route and 38 are market practice, and each is labelled where it is asked.

Of the 7 gates a direct listing would score, 1.9, 2.2a, 3.2 and 4.1 rest on a rule that does not bind on your route, so they are scored as high-priority findings rather than gates. The other 3 are still gates, and each gate says why where it is asked.

Where a label rests on our reading of the rules rather than on settled text it says so. The route, and whether that reading holds, is for your counsel.

Your company

The company is incorporated outside the UK — this route allows nothing else — so the audit reports on its accounts have to come from a firm on the FRC's register of third-country auditors. The register as read on 2026-09-09 lists 126 firms, and the free auditor check at /auditor looks yours up by its registered name. If your firm is not on it, a registered firm signs or yours registers first.

Practice treats that regime as reaching a depositary-receipt admission, where the securities admitted are the certificates; whether that is beyond argument is a question for your counsel.

A framework outside PRM 4.4.12R's list is restated into UK-adopted international accounting standards (PRM 4.4.13R) for every year the prospectus carries — the latest three, or the shorter period the company has been operating (PRM App 2 Annex 1, item 18.1.1). Those years have already closed, so the restatement belongs near the start of the timetable.

That this accounting rule reaches a GDR prospectus in full is our reading — the PRM 4.4.14R(2) exemption is written for non-equity securities — and your counsel decides it.

DTR 7.1 does not bind a company incorporated outside the UK: DTR 1B.1.2R applies it only to an issuer required to appoint a statutory auditor under the Companies Act 2006, which an overseas company is not, so 2.2a is scored as a high-priority finding rather than a gate. The work does not go with the rule. The corporate governance statement still has to describe the board's committees and the internal control and risk management systems over financial reporting (DTR 7.2), so an absence has to be written down, and the banks' and the reporting accountant's diligence look for somebody doing the job.

DTR 7.1.3R describes a body, or bodies, that monitor the financial reporting process, internal control and risk management, the statutory audit and the auditor's independence, and that run the choice of auditor; DTR 7.1.1AR and 7.1.2AR add a majority of independent members, an independent chair and accounting or audit competence.

A revision commission elected by the shareholders' meeting may do some of that and not the rest, so test it against the list rather than against its name, and answer 2.2a for whichever body or bodies do all of it.

This note changes nothing that is scored — not the verdict, the coverage or any finding.

For the timetable, early

The calendar places these against your admission month →

An auditor on the FRC's third-country register. Only a registered firm may sign the audit reports on the company's accounts, and registering is a process with its own lead time — so it starts near the beginning, not in the last month.
Restating the historical financial information. PRM 4.4.13R restates every year the prospectus carries into UK-adopted international accounting standards, and those years have already closed — it is work on history, and it starts early.
Setting up the body that does the DTR 7.1.3R job. A board resolution at the least. Whether the company's charter has to change first is a question for your home counsel, and the answer decides how early it has to start.

Criteria met

47 of 73 criteria met · 24 open, 2 unsure · all 3 gate items open

met 47unsure 2open 24

This counts how much of the work is done. It is not a verdict on whether you can list — that is the line above, and one open gate item settles it however high this figure goes.

Every one of the 73 FPPP criteria was put to you.

19 criteria count as open despite being answered yes: each was claimed while something it is impossible without was answered no. One of the two answers is wrong, and until you know which, the claim cannot be counted.

13 of the criteria counted here must hold at every one of the 6 entities you declared, not at the holding company alone. This scan asks each question once, at group level, so a "met" records the answer you gave for the group. Group coverage on those is the weakest entity rather than the average, so the figure above can only be lower once it is asked per entity — never higher.

Where it sits, by area and by function

By FPPP area

1. Directors' risk assessment of FPP 2 of 9 met · 7 open
2. High-level reporting environment 6 of 12 met · 6 open · the gate item is open
3. Forecasting and budgeting 8 of 8 met
4. Management reporting framework 4 of 6 met · 2 open
5. ESG, climate and sustainability reporting 4 of 9 met · 5 open
6. Significant transaction complexity 4 of 6 met · 1 open, 1 unsure
7. Strategic projects and initiatives 8 of 8 met
8. Financial accounting and reporting 5 of 7 met · 2 open · all 2 gate items open
9. IT environment 6 of 8 met · 1 open, 1 unsure

By owning function

The default owner of each criterion, most outstanding first. It is where the work lands, not who is to blame for it.

Compliance & Risk 2 of 12 met · 10 open · the gate item is open
CFO / Finance 20 of 26 met · 5 open, 1 unsure · the gate item is open
ESG 3 of 6 met · 3 open
IT 6 of 8 met · 1 open, 1 unsure
Board / Company Secretary 5 of 7 met · 2 open
Legal 2 of 4 met · 2 open · the gate item is open
Internal Audit 0 of 1 met · 1 open
Strategy 7 of 7 met
Investor Relations 2 of 2 met

Blocking

High

Medium

Low

Priority against effort

Two axes, held apart deliberately. Priority is what a sponsor needs before admission; effort is how much calendar time it takes. Collapsed into one score they trade against each other, and they should not: anything in the High-effort column starts this month whatever its priority, because that effort is time no budget buys back. Read down the column for the schedule, across the row for the sponsor.

Priority \ Effort	Low	Medium	High
Blocking	—	8.6 MAR and inside information	2.3 ICFR framework 8.1 IFRS accounting policies
High	—	1.2 Group risk register 4.4 Out-of-cycle escalation 6.2 Accounting and tax on complex deals	2.4 Delegation of authority 2.6 Whistleblowing policy 2.10 Accounting records 4.1 Monthly management accounts 5.3 Health and safety policy 5.4 Business ethics and anti-corruption 6.5 Related-party transactions 9.2 Logical access controls 9.3 Segregation of duties
Medium	1.3 Risk categories covered 1.5 Risk owners 1.8 FPP-relevant risk factors 2.7 Control deficiency remediation 5.5 Climate risk in the risk matrix	1.6 Mitigation actions 1.9 Directors' FPPP risk assessment 5.8 Corporate governance statement	1.7 Board and committee challenge 5.2 Environmental policy
Low	—	—	2.8 Internal audit

Low: Write down and approve what already happens — days to a fortnight.
Medium: Build a process and run it enough to evidence it — one to three months.
High: Needs operating history, a system change or a third party — three months+, and more money does not make it faster.

Start these this month

14 findings need operating history, a system change or a third party. They set the admission date rather than the budget, and adding money or people does not make them finish sooner.

2.3 ICFR framework — External advisor
8.1 IFRS accounting policies — External advisor
2.4 Delegation of authority — Company
2.6 Whistleblowing policy — Company
2.10 Accounting records — Company
4.1 Monthly management accounts — Company
5.3 Health and safety policy — Company
5.4 Business ethics and anti-corruption — Company
6.5 Related-party transactions — External advisor
9.2 Logical access controls — Company
9.3 Segregation of duties — External advisor
1.7 Board and committee challenge — Company
5.2 Environmental policy — Company
2.8 Internal audit — External advisor

Findings

26 open, carrying the same fields a phase-1 FPPP red-flag report sets out in columns. The PDF keeps the columns; on screen the two prose fields get their own line, because a 230-character observation in a 190px column is not a column. 9 are marked via — they collapse when their root closes and are not separate workstreams. Counting them as independent findings is how a gap list becomes a scarier number than the company actually has.

#	Area	Topic	Priority	Effort	Who	Phase
2.3	2. High-level reporting environment	ICFR frameworkFoundation ×2	Blocking	High	External advisor	Pre-IPO
	Observation Not in place. Recommendation 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.
8.1	8. Financial accounting and reporting	IFRS accounting policiesFoundation ×4	Blocking	High	External advisor	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation A group IFRS accounting policy manual, board-approved, with evidence it is the manual each perimeter entity actually applies.
8.6	8. Financial accounting and reporting	MAR and inside information	Blocking	Medium	External advisor	Pre-IPO
	Observation Not in place. Recommendation 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.
2.4	2. High-level reporting environment	Delegation of authority	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation 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.
2.6	2. High-level reporting environment	Whistleblowing policy	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation Names the reporting channel, protects the reporter from retaliation, and states how reports are escalated, investigated and tracked to conclusion.
2.10	2. High-level reporting environment	Accounting records	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation Records support production of management information within the stated close timetable.
4.1	4. Management reporting framework	Monthly management accountsFoundation ×3	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation A monthly pack containing all six elements, with divisional reporting for every entity in the IPO perimeter.
5.3	5. ESG, climate and sustainability reporting	Health and safety policy	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation Sustainability and health-and-safety policies or procedures, where applicable to the operations, with evidence of implementation across the material ones.
5.4	5. ESG, climate and sustainability reporting	Business ethics and anti-corruption	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation A code of ethics, anti-corruption policies and whistleblowing procedures, each formally approved at every entity in the IPO perimeter.
6.5	6. Significant transaction complexity	Related-party transactions	High	High	External advisor	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation A maintained related-party register plus the documented procedure covering identification, assessment against the threshold, approval, and disclosure.
9.2	9. IT environment	Logical access controls	High	High	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation A current user access list for each key financial application, showing access restricted to authorised users, with joiners and leavers reflected.
9.3	9. IT environment	Segregation of duties	High	High	External advisor	Pre-IPO
	Observation Not known to be in place. For a sponsor, not knowing is the same answer as no. Recommendation 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.
1.2	1. Directors' risk assessment of FPP	Group risk registerFoundation ×7	High	Medium	Company	Pre-IPO
	Observation Not in place. Recommendation A current group risk register giving, for each risk, likelihood, financial impact, owner and mitigation.
4.4	4. Management reporting framework	Out-of-cycle escalation	High	Medium	Company	Pre-IPO
	Observation Answered yes — this has to hold at every one of the 6 entities in your IPO perimeter, and you told us group policies are not adopted at all of them. Group readiness is the weakest entity, not the average — so this reads as not done. Recommendation States the materiality threshold, the escalation route to the board, and the timescale — with the link to the inside-information assessment made explicit.
6.2	6. Significant transaction complexity	Accounting and tax on complex deals	High	Medium	External advisor	Pre-IPO
	Observation Not known to be in place. For a sponsor, not knowing is the same answer as no. Recommendation States who assesses accounting and tax implications, at what point in the transaction, and how the assessment reaches the board before commitment.
1.7	1. Directors' risk assessment of FPP	Board and committee challengevia 1.2	Medium	High	Company	Pre-IPO
	Observation Answered yes — the board and committee review the register, and there is no register to review — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation Minutes record the committee reviewing the risk register and challenging management on it — not merely receiving it.
5.2	5. ESG, climate and sustainability reporting	Environmental policy	Medium	High	Company	Pre-IPO
	Observation Not in place. Recommendation An environmental policy carrying board approval, with evidence of its implementation at each entity across the group.
1.6	1. Directors' risk assessment of FPP	Mitigation actionsvia 1.2	Medium	Medium	Company	Pre-IPO
	Observation Answered yes — mitigating actions are tracked per risk on the register, and there is no register to track them against — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation Each risk carries mitigating actions with a status and a review date.
1.9	1. Directors' risk assessment of FPP	Directors' FPPP risk assessmentvia 1.2	Medium	Medium	Us	Pre-IPO
	Observation Answered yes — the directors' assessment rests on the identified risks, and no group risk register exists to draw them from — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation A single directors' FPPP risk assessment addressing each of the seven areas by name, and stating for each the procedures relied upon.
5.8	5. ESG, climate and sustainability reporting	Corporate governance statementvia 2.3	Medium	Medium	External advisor	Pre-IPO
	Observation Answered yes — the corporate governance statement must describe the internal control system for financial reporting, and no ICFR framework has been documented to describe — see criterion 2.3 (ICFR framework), which you told us is not in place. Closing 2.3 resolves this; it is not a separate workstream. Recommendation A draft corporate governance statement in which each applicable DTR and UK Corporate Governance Code requirement is addressed, and readable against them.
1.3	1. Directors' risk assessment of FPP	Risk categories coveredvia 1.2	Medium	Low	Company	Pre-IPO
	Observation Answered yes — risk categories are recorded on the risk register, so there is nothing for the identification process to populate — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation Each of the five categories is represented by at least one identified risk, and the register shows which category each risk belongs to.
1.5	1. Directors' risk assessment of FPP	Risk ownersvia 1.2	Medium	Low	Company	Pre-IPO
	Observation Answered yes — risk owners are assigned against entries on a register, and there is no register to assign them on — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation Every risk names an accountable individual.
1.8	1. Directors' risk assessment of FPP	FPP-relevant risk factorsvia 1.2	Medium	Low	Company	Pre-IPO
	Observation Answered yes — FPP-relevant risks are flagged on the register, and there is no register to flag them on — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation Risks bearing on financial position and prospects are marked as such and each maps to the named procedure that addresses it.
2.7	2. High-level reporting environment	Control deficiency remediationvia 2.3	Medium	Low	Us	Pre-IPO
	Observation Answered yes — an internal control deficiency is a departure from a defined control framework, and no ICFR framework has been documented — see criterion 2.3 (ICFR framework), which you told us is not in place. Closing 2.3 resolves this; it is not a separate workstream. Recommendation States how deficiencies are logged, rated for severity, communicated, assigned and cleared, with timescales and an escalation threshold to the audit committee.
5.5	5. ESG, climate and sustainability reporting	Climate risk in the risk matrixvia 1.2	Medium	Low	Company	Pre-IPO
	Observation Answered yes — climate risks are integrated into the Group Risk Matrix, and no group risk register exists to integrate them into — see criterion 1.2 (Group risk register), which you told us is not in place. Closing 1.2 resolves this; it is not a separate workstream. Recommendation An ESG risk matrix in which physical and transition climate risks are each separately identified, with the supporting climate risk assessment referenced.
2.8	2. High-level reporting environment	Internal audit	Low	High	External advisor	Pre-IPO
	Observation Not in place. Recommendation 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.

How the foundations get closed

6 of the open findings are either gates or criteria that at least two others are impossible without. The Recommendation column above is the acceptance condition — what has to be true when somebody looks. This is the other half: what closing it involves, in the order the work runs. Where calendar time is the binding input rather than money, the first step says so.

2.3ICFR frameworkBlockingHigh effort · External advisor · 2 criteria stand on it

1Start now, and for a reason that is not urgency: operating effectiveness testing needs a period of history behind it, so a late start cannot be bought back with people or money.
2Scope down from the financial statement line items that matter to the controls that produce them. A list assembled bottom-up from the controls that happen to exist documents the current state rather than the required one.
3Name an individual control owner for each key control. An owner that is a department cannot be asked what happened in March.
4Separate design from operating effectiveness in the document, and state who tests each and on what cycle. Design and implementation is the bar at the confirmation (FCA TN 708.4); the operating record is what phase 2 reads.
5Roll it out at every entity in the perimeter, not only the holding company. This criterion is scored at the weakest entity, so a framework adopted in four of seven places scores as four of seven, not as most of the way.

8.1IFRS accounting policiesBlockingHigh effort · External advisor · 4 criteria stand on it

1Board-approve one group manual, then test whether each perimeter entity actually applies it. The second half is the half that fails.
2List the entities reporting under local GAAP with the conversion path for each. The conversion has to run off this manual rather than off a separate working practice built in the finance team.
3Write down the key judgements and estimates with the reasoning, not only the policy. They are what a reporting accountant reads first.
4Do this before the historical financial information is prepared. Without it the numbers in the prospectus have no stated basis, and inconsistency between entities surfaces at conversion — late, and in public.

8.6MAR and inside informationBlockingMedium effort · External advisor

1Open the insider list now. UK MAR binds an issuer from the request for admission, not from the first day of dealings, and the IPO is itself the largest inside-information event the company has had.
2Name an owner for the list inside the company. Article 18 is not transferred by asking an adviser to keep it.
3Write the assessment route down: who decides whether something is inside information, within what time, and who can call a holding announcement.
4Stand up the PDMR notification process and tell the PDMRs it exists. The obligation lands on individuals who have not had it before.
5Run the procedure once over a real event from the last quarter. A procedure nobody has used is a document.

4.1Monthly management accountsHighHigh effort · Company · 3 criteria stand on it

1Produce the pack every month starting with this month, even in an imperfect form. The evidence here is a run of months and it is the one input no budget shortens.
2Publish a close calendar with an issue date for each month, then record the actual issue date against it. The calendar is the plan; the log of hits and misses is the evidence.
3Extend divisional reporting to every entity in the perimeter, dormant ones included. A perimeter entity absent from the pack is a hole in the consolidation and it is found at conversion.
4Add the missing elements — P&L, cash flow, balance sheet, working capital, KPIs — as identifiable items rather than one composite page, so completeness can be checked at a glance.
5Take the pack to the board monthly and keep the minute. A pack produced and never read evidences a process at the wrong level.

1.2Group risk registerHighMedium effort · Company · 7 criteria stand on it

1Do this before the criteria that stand on it. Each of them draws its content from the register, so closing them first means closing them twice.
2Give every risk a named individual owner and a dated mitigation action. A departmental owner cannot be chased and does not satisfy a reviewer.
3Put climate risk, physical and transition, in the group register rather than in a separate ESG document. One artefact then answers both the risk criterion and the ESG one.
4Set a review cycle of six months or shorter and keep the revision history. A register last touched eighteen months ago reads worse than a thin one updated last quarter, because the dates are what a reviewer reads first.
5Take it to the audit and risk committee for challenge, and check the minutes record challenge rather than receipt.

1.9Directors' FPPP risk assessmentMediumMedium effort · Us

1Put one named owner on the document itself, not one per area. Seven part-owners produce seven annexes and no assessment.
2Use the seven areas the criterion names as the section headings, so a reader can check coverage without reading the prose.
3In each section write the risk first and the procedure relied on second, and name the artefact that evidences the procedure. A procedure with no named artefact is a claim, and phase 1 asks for the artefact.
4Where a procedure is not yet in place, say so and attach the plan with a date. FCA TN 708.4 contemplates gaps identified and undertaken to be addressed at the confirmation, not gaps closed already — but it does not contemplate gaps unstated.
5Route the draft through the audit committee before the board, and keep both minutes. The bar at the confirmation is designed, documented, approved and communicated; the minutes are the last two words.

These steps are our considered account of how the work runs, not a requirement of the standard and not the sponsor’s or the reporting accountant’s instruction. Nothing here says what the outcome of doing them is, because nobody can.

The order of work

This is the order the work is worth doing in, on the answers given. It is not a project plan signed off by anybody, not a requirement of the standard, and not the sponsor's or the reporting accountant's instruction.

How many of these can you run at once?

26 open items in 7 waves at 4 in flight at once. At 2 it is 13 waves; at 8 it is 4. The effort bands did not move between those three figures — how many things you can run at once is what changes the shape of the programme, and it is the one input here that is yours rather than ours.

2 at once

13 waves

3 at once

9 waves

4 at once

7 waves

6 at once

5 waves

8 at once

4 waves

16 of the 26 open items your own team can close. 8 need an external specialist — a reporting accountant, listing counsel, tax or a model review — and that is a procurement lead time before any work starts on them. 2 are work this product does.

3 items cannot start until another function delivers something first. Those are the ones to watch: an item late inside one lane is that lane's problem, and an item late across two is nobody's until it is everybody's.

9 of the 14 heaviest-band items could start now and cannot, because the first wave holds 4. The findings above say every one of them wants to start immediately, since the binding input on them is calendar time; this says how many of them your capacity actually admits. Both are true, and the distance between them is what the plan turns on — it is why this page asks how many you can run rather than adding up how long each takes. A further 2 are waiting on another open item, which capacity does not move.

Your target admission puts you at T-9 on the conventional phasing, and no item here is first expected earlier than that.

Function \ Wave	1	2	3	4	5	6	7
Compliance & Risk	2.3 ICFR framework	1.2 Group risk register 2.6 Whistleblowing policy	1.7 Board and committee challenge	5.4 Business ethics and anti-corruption	1.6 Mitigation actions	1.3 Risk categories covered 1.5 Risk owners 1.8 FPP-relevant risk factors	2.7 Control deficiency remediation
Board / Company Secretary	—	—	—	—	1.9 Directors' FPPP risk assessment 5.8 Corporate governance statement	—	—
CFO / Finance	8.1 IFRS accounting policies	4.1 Monthly management accounts 2.4 Delegation of authority	2.10 Accounting records	—	4.4 Out-of-cycle escalation	6.2 Accounting and tax on complex deals	—
Internal Audit	—	—	2.8 Internal audit	—	—	—	—
ESG	—	—	5.2 Environmental policy	5.3 Health and safety policy	—	—	5.5 Climate risk in the risk matrix
Legal	8.6 MAR and inside information	—	—	6.5 Related-party transactions	—	—	—
IT	9.2 Logical access controls	—	—	9.3 Segregation of duties	—	—	—

A wave is an ordering, not a length of time. The effort bands describe single items and say nothing about how many can run at once, so nothing here is added up and nothing here is a date. What sets the shape is the number of items in flight, which is yours to set.

Compliance & Riskwaves 1–7

10 open. 8 of the 10 your own team can close; 1 needs an external specialist, so it carries a procurement lead time before any work starts, and 1 is work this product does.

Framework document ×1

Committee minutes ×1

Policy ×2

Documented procedure ×1

Board / Company Secretarywave 5

2 open. None of them can be closed inside the company; 1 needs an external specialist, so it carries a procurement lead time before any work starts, and 1 is work this product does. This lane cannot finish on its own: it waits on Compliance & Risk.

Framework document ×1

Documented procedure ×1

CFO / Financewaves 1–6

6 open. 4 of the 6 your own team can close; 2 need an external specialist, so they carry a procurement lead time before any work starts.

Policy ×1

Management accounts ×2

Matrix ×1

Documented procedure ×2

Internal Auditwave 3

1 open. It cannot be closed inside the company; 1 needs an external specialist, so it carries a procurement lead time before any work starts.

Terms of reference ×1

ESGwaves 3–7

3 open. All 3 your own team can close; none needs an outside specialist. This lane cannot finish on its own: it waits on Compliance & Risk.

Policy ×2

Legalwaves 1–4

2 open. None of them can be closed inside the company; 2 need an external specialist, so they carry a procurement lead time before any work starts.

ITwaves 1–4

2 open. 1 of the 2 your own team can close; 1 needs an external specialist, so it carries a procurement lead time before any work starts.

System configuration record ×2

Every item, in the order it is worth doing

The line under each row is the reason it sits where it does. It is our derivation and you are meant to be able to argue with it — which you cannot do with a plan that only shows you the bars.

Wave	Ref	Item	Function	Artefact	Effort	Who	First seen at
1	2.3	ICFR framework	Compliance & Risk	Framework document	High	External advisor	T-9
	Nothing blocks it, so it starts in the first wave. It is a gate: the confirmation cannot be given without it.
1	8.1	IFRS accounting policies	CFO / Finance	Policy	High	External advisor	T-9
	Nothing blocks it, so it starts in the first wave. It is a gate: the confirmation cannot be given without it.
1	8.6	MAR and inside information	Legal	Register	Medium	External advisor	T-9
	Nothing blocks it, so it starts in the first wave. It is a gate: the confirmation cannot be given without it.
1	9.2	Logical access controls	IT	System configuration record	High	Company	T-6
	Nothing blocks it, so it starts in the first wave. Open work is stacked behind it one level deep, so closing it first is what stops the rest being done twice.
2	1.2	Group risk register	Compliance & Risk	Register	Medium	Company	T-6
	Nothing blocks it — it is in wave 2 only because the earlier waves were full at 4 in flight. Open work is stacked behind it one level deep, so closing it first is what stops the rest being done twice.
2	4.1	Monthly management accounts	CFO / Finance	Management accounts	High	Company	T-6
	Nothing blocks it — it is in wave 2 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
2	2.4	Delegation of authority	CFO / Finance	Matrix	High	Company	T-9
	Nothing blocks it — it is in wave 2 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
2	2.6	Whistleblowing policy	Compliance & Risk	Policy	High	Company	T-9
	Nothing blocks it — it is in wave 2 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
3	1.7	Board and committee challenge	Compliance & Risk	Committee minutes	High	Company	T-6
	Cannot start before 1.2, which is also open. The binding input is calendar time, which is the one thing nothing else buys back.
3	2.8	Internal audit	Internal Audit	Terms of reference	High	External advisor	T-6
	Nothing blocks it — it is in wave 3 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
3	2.10	Accounting records	CFO / Finance	Management accounts	High	Company	T-9
	Nothing blocks it — it is in wave 3 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
3	5.2	Environmental policy	ESG	Policy	High	Company	T-6
	Nothing blocks it — it is in wave 3 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
4	5.3	Health and safety policy	ESG	Policy	High	Company	T-6
	Nothing blocks it — it is in wave 4 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
4	5.4	Business ethics and anti-corruption	Compliance & Risk	Policy	High	Company	T-6
	Nothing blocks it — it is in wave 4 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
4	6.5	Related-party transactions	Legal	Register	High	External advisor	T-6
	Nothing blocks it — it is in wave 4 only because the earlier waves were full at 4 in flight. The binding input is calendar time, which is the one thing nothing else buys back.
4	9.3	Segregation of duties	IT	System configuration record	High	External advisor	T-9
	Cannot start before 9.2, which is also open. The binding input is calendar time, which is the one thing nothing else buys back.
5	4.4	Out-of-cycle escalation	CFO / Finance	Documented procedure	Medium	Company	T-6
	Nothing blocks it — it is in wave 5 only because the earlier waves were full at 4 in flight.
5	1.6	Mitigation actions	Compliance & Risk	Register	Medium	Company	T-9
	Cannot start before 1.2, which is also open.
5	1.9	Directors' FPPP risk assessmentHandoff	Board / Company Secretary	Framework document	Medium	Us	T-6
	Cannot start before 1.2, which is also open.
5	5.8	Corporate governance statementHandoff	Board / Company Secretary	Documented procedure	Medium	External advisor	T-6
	Cannot start before 2.3, which is also open.
6	6.2	Accounting and tax on complex deals	CFO / Finance	Documented procedure	Medium	External advisor	T-6
	Nothing blocks it — it is in wave 6 only because the earlier waves were full at 4 in flight.
6	1.3	Risk categories covered	Compliance & Risk	Register	Low	Company	T-6
	Cannot start before 1.2, which is also open.
6	1.5	Risk owners	Compliance & Risk	Register	Low	Company	T-6
	Cannot start before 1.2, which is also open.
6	1.8	FPP-relevant risk factors	Compliance & Risk	Register	Low	Company	T-6
	Cannot start before 1.2, which is also open.
7	2.7	Control deficiency remediation	Compliance & Risk	Documented procedure	Low	Us	T-6
	Cannot start before 2.3, which is also open.
7	5.5	Climate risk in the risk matrixHandoff	ESG	Register	Low	Company	T-6
	Cannot start before 1.2, which is also open.

Company: Company — internal. The knowledge is in the building; the work is not done.
External advisor: External advisor — a specialist you do not have in-house, so it carries a procurement lead time.
Us: Us — work this product does. Kept deliberately narrow.

First seen at is the point on the published phasing at which the reporting accountant expects to see something, derived from the criterion’s own properties by the same rule the timetable prints. A row in amber is one the phasing wants earlier than the target you gave.

By FPPP area

Each area takes its worst finding, not its average. A group policy three subsidiaries never adopted is not 60% done.

01Directors' risk assessment of FPP7 open / 9HighHigh effort

02High-level reporting environment6 open / 12BlockingHigh effort

03Forecasting and budgeting0 open / 8Clear—

04Management reporting framework2 open / 6HighHigh effort

05ESG, climate and sustainability reporting5 open / 9HighHigh effort

06Significant transaction complexity2 open / 6HighHigh effort

07Strategic projects and initiatives0 open / 8Clear—

08Financial accounting and reporting2 open / 7BlockingHigh effort

09IT environment2 open / 8HighHigh effort

A4 landscape, built in this tab. Nothing is uploaded.

What this example leaves out

The three register checks are missing, and they cannot be faked here: each one is a lookup against a public register, and its result means nothing without the names it was given and the date the register was read. They are free and public in their own right, so run them on real names rather than reading invented ones.

Auditor eligibility→Sanctions sweep→Perimeter vs GLEIF→

Run the free scan on your own answers What the full diagnostic covers