Governance Featured

Provision 29: tackling governance and engagement

Liam Donovan
by Liam Donovan
2 min read
Jun 30, 2026

A poll in March of our risk leader network revealed that 50% of companies have defined their approach to Provision 29 of the updated UK Corporate Governance Code. Notably, some organisations are even planning to issue their disclosure ahead of schedule.

With the majority of UK-listed entities preparing for compliance by the 2026/27 reporting period, we have been facilitating collaborations between risk leaders, to share the operational steps and practical strategies required to meet the new standards.
 
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A primary focus of these in-depth workshops is the challenge of effective governance and engagement, specifically regarding board-level interaction. Here are two ways that risk leaders are tackling the challenge:

1. Continuous engagement

Rather than relying on a single, year-end update to the Audit and Risk Committee (ARC) and board on the effectiveness of material controls, risk leaders are increasingly adopting a model of continuous engagement.

The benefit of this ‘little and often’ approach is that it provides leadership with greater confidence in the final declaration. By being involved throughout the annual cycle, they are better positioned to help shape the declaration before the reporting deadline.

For example, one company in our membership has added a standing item to their quarterly risk committee meetings on progress towards Provision 29. This ensures it remains a formal priority every time they meet with senior management.

View our Talk on-demand: UK Corporate Governance Code changes
Watch our 30 minute talk to get ideas and validate your approach to Provision 29. In the talk, we share the steps your peers are taking to prepare for the code reform, with a particular focus on Provision 29.
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2. Reporting and delegation 

Risk and assurance leaders are taking different approaches to reporting on controls to the ARC and board. While some of our members prefer frequent, light-touch reporting, others opt for a more detailed and comprehensive overview with longer intervals.

An important consideration underpinning their approaches is ensuring reports are digestible for time-poor executives and members of the board. This has led to some organisations keeping their risk and control papers separate, so that material controls updates are distinct from regular risk reporting.

Ultimately, the focus is dictated by leadership priorities around material controls. As one risk leader noted at a recent collaboration, it’s the substance of the controls that really matters to their board. Clear delegation of other tasks, such as asking Legal to formulate the wording of the final declaration, can allow additional focus to be applied in the right areas.

Hear insights from peer at our upcoming and on-demand 30-minute talks:

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What's next?

The prevailing sentiment among risk leaders is that Provision 29 is a progression of Provision 28, not a total revolution. By prioritising the substance of controls and maintaining a high-frequency feedback loop with the ARC and board, organisations are well positioned to meet the new standards.

Through continuous engagement, targeted education, and streamlined reporting, companies are aiming to make the 2026/27 reporting cycle a natural extension of their existing risk management framework, ensuring compliance is both practical and integrated.

Want to know more about how your peers are approaching the upcoming changes to the UK Corporate Governance code? Catch up on our recent RLN Talk, where we share some of the insights and knowledge of the network on how they’re preparing.

 
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