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FPPP post-mortems29 August 2026

Where the procedures failed, and what would have caught it

A casebook, not a news feed. Each entry takes a case where a regulator, a court or the company itself has said that financial position and prospects procedures fell short, and names the criterion in the pack whose evidence test addresses it.

Archived edition — a finding may have been appealed or overturned since. Read the current one

The takeaway

In all three notices the numbers existed somewhere in the business before they reached the market; what the regulator found missing was the procedure that made them supported, aggregated and challenged on the way up.

  • Write the basis for each key judgement next to the judgement, with the approver's name on it.
  • Make one report reconcile to the next: a divisional view and a board view that differ need a documented explanation, not a rewrite.
  • Roll every project and every contract up against the group plan, not only against its own budget.
  • Decide the escalation threshold before you need it — all three findings turn on information that moved too slowly, not information nobody had.

Seed edition · three cases in which a regulator made an express finding about the issuer's own procedures, systems and controls · sources retrieved 29 August 2026

A case earns a place here only where a regulator, a court or the company itself has said the procedures fell short. A profit warning, a share-price fall or a restatement is not, on its own, evidence of that — and a case that goes no further than a disclosure breach is left out, however well known it is.

1. Accounting judgements that no procedure required anyone to support or challenge

On 3 March 2026 the FCA published a final notice imposing a penalty of £12,993,700 on John Wood Group PLC for contraventions of Listing Rule 1.3.3R and Listing Principle 1, the requirement to establish and maintain adequate procedures, systems and controls. The Authority found that during the period from 1 January 2023 to 7 November 2024 Wood Group's "control framework was insufficiently robust to ensure that, where accounting judgements needed to be made in relation to its projects, they were made appropriately and in compliance with applicable accounting standards." The notice sets out what the Authority considers such a framework should deliver: judgements on individual projects that are "clear, consistent and well supported", inconsistencies "identified and resolved in a timely fashion with appropriate challenge from senior staff", and adequate policies governing provisions, contingencies and dispensations. The FCA found Wood Group failed to meet those standards and that its processes "enabled, rather than prevented, inappropriate decisions" — among them the release of provisions held against specific project risks in order to offset losses elsewhere in the business. The Authority treated as an aggravating factor that Wood Group was already aware of the risk of similar failings in its financial culture as a result of an internal review it had conducted in 2022. Wood Group agreed to resolve the matter and qualified for a 30% settlement discount.

What would have caught it: the pack's test at fr-3 is not "are judgements made" but a schedule of key judgements and estimates giving, for each, the assumption used, the basis for it, and who approved it. A provision released against one project to absorb a loss on another does not survive that test, because the basis column has to be written down and attributed before anyone signs it. re-3 asks the structural half of the same question — key financial reporting controls, each with a named owner and a stated cycle for assessing whether it actually operates — and fr-1 asks whether the group's board-approved IFRS policies are the ones each entity applies, which is where consistency of contract accounting either exists or does not. The criterion this case turns on hardest is re-7: a documented route by which an identified deficiency is rated, assigned, tracked and cleared to a deadline. An internal review that finds a risk and a register that never closes it are the same finding recorded twice.

Touches fr-1, fr-3, re-3, re-7 — check yours · run the free scan

2. A board pack that disagreed with the business unit's own numbers

On 16 February 2026 the FCA published a final notice censuring Carillion plc (in liquidation) for contraventions of Article 15 of the Market Abuse Regulation, Listing Rule 1.3.3R, Listing Principle 1 and Premium Listing Principle 2. The Authority said that, but for Carillion's financial circumstances, it would have imposed a penalty of £37,910,000. On procedures, the finding is precise: between 1 July 2016 and 10 July 2017 Carillion's systems, procedures and controls were not sufficiently robust to ensure that contract accounting judgements made in its UK construction business were "appropriately made, recorded and reported internally to the Board and the Audit Committee". The notice describes two parallel sets of numbers. Internal reporting within the construction business "highlighted large and increasing risks associated with the financial performance" of its projects, while the monthly Overtrade Report and quarterly Major Project Status Report that reached the board and the audit committee "painted a much more optimistic picture". The FCA found the board and the audit committee were not made aware of those risks and were therefore "hampered in providing proper oversight". The Authority found three former executive directors had acted recklessly and attributed their state of mind to the company; it fined them in related final notices, and the former chief executive withdrew his challenge to the FCA's decision.

What would have caught it: mr-1 requires the monthly pack to carry divisional performance reporting for every entity inside the perimeter — which is the control that puts a subsidiary's own view of its projects in front of the board rather than a summary written above it. The test that bites here is reconciliation and provenance: mr-6 asks for at least one recorded instance of the board being told about a material financial event between scheduled reporting dates, and mr-4 asks for a stated materiality threshold, a named escalation route and a timescale, with the link to the inside-information assessment made explicit. Where a divisional report and a board report can differ by an order of magnitude and no procedure requires the difference to be explained, the escalation route does not exist however many committees are named on the chart. ra-7 is the check on the receiving end: minutes that record the committee challenging management on what it was given, not merely receiving it.

Touches mr-1, mr-4, mr-6, ra-7 — check yours · run the free scan

3. Project reporting that was never measured against the group's own budget

Older, and included because the failure mode is structural rather than topical. On 15 March 2013 the FSA published a final notice imposing a penalty of £2,428,300 on Lamprell plc, a UK-listed engineering and contracting group based in the United Arab Emirates, for breaching what was then Listing Principle 2 — the same obligation to maintain adequate procedures, systems and controls that now sits in the Listing Principles at UKLR 2 — together with DTR 1.3.4R and DTR 2.2.1R. The regulator found "serious systems and controls failings" which meant Lamprell "could not at that time adequately monitor the full impact of operational issues on the Company's financial performance for the year", and that its financial oversight "had not grown and developed in line with the Company's operational growth". The notice names three specific defects: project reporting considered each project against that project's own budget and never against the company's budget for the financial year; the award of new business was not tracked against budget, so a delayed award was not automatically assessed for its effect on the plan; and the company lacked sufficient visibility of staff utilisation, which the FSA recorded as a key reason for the revised figures. The consequence the regulator drew is the one worth keeping: Lamprell "did not recognise its deteriorating financial position as soon as it should have done", and by 29 April 2012 had enough information that it should at least have issued a holding statement. It settled early and received a 30% discount.

What would have caught it: fb-5 is the direct answer — actual against budget and against forecast, with written explanation of material variances in both directions, in a pack the board demonstrably received. Reporting that compares a project only to its own budget passes a project test and fails this one, because nothing in it ever rolls up to the number the market was given. fb-3 supplies the missing trigger: a stated re-forecast cadence, the events that force an out-of-cycle re-forecast, and a path by which actuals feed back into the model. fb-7 is the outward-facing half — who tracks consensus, how the company's own forecast is compared against it, and the threshold at which an announcement is considered — and fr-6 carries the endpoint the FSA identified, a documented procedure for assessing and escalating inside information that says when a holding announcement is issued.

Touches fb-3, fb-5, fb-7, fr-6 — check yours · run the free scan

Sources

It was found in their procedures. Is it open in yours?

Every case above names the criteria it touches. The free scan walks 15 of the 73 across all nine FPPP areas, checks your answers against each other, and tells you where they contradict. It runs entirely in your browser — nothing is sent anywhere, and nothing is stored.

Run the free scan →Read all 73 criteria

Published Thursdays. This is a casebook rather than a news feed: an older case that has not been covered is as welcome as a recent one. Compiled from public regulatory notices, court judgments and companies’ own announcements, and cited to them. It is not legal advice, not investment advice, and not a comment on any company’s prospects or securities.