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Disclosure Log 2025
DISCLOSURE LOG- FOIA Requests
Date of response: 02/05/2025
Nature of request: Do you currently use any Contractors or external consultants within the Cyber Security function? (How many if so)
Our response follows the order of your request. The FRC does not currently use any contractors or external consultants within its cyber security function. The FRC uses a managed service partner within its cyber security function.
Nature of request: If not, have you had any cyber security contractors previously?
The FRC has not previously used cyber security contractors.
Nature of request: Do you have an allocated budget for Cyber Security spending?
The FRC does not have a separate allocated budget for cyber security expenditure. All expenditure for cyber security sits within the FRC IT budget.
Date of response: 28/04/2025
Nature of request:
- A copy of all 3rd party communications to the FRC regarding TM1, its directors, and Auditors, that you hold on file. This regardless of timeline.
- The names of any personnel working for, or with, the FRC and who at any time have held a position at PKF.
You clarified that:
- 'TM1, it's directors, and Auditors' means the current directors of TM1, as listed as active directors on Company House records, and PKF Littlejohn LLP, as the current auditor of TM1.
- 'This regardless of timeline' applies to copies of all '3rd party communications to the FRC' held on file from 1 November 2021.
- references to 'TM1' are to be taken as references to Technology Minerals Plc
- references to 'PKF' are to be taken as references to PKF Littlejohn LLP.
Response:
The FRC may hold the information requested but estimates that establishing whether it holds the information will exceed the cost limit set out in the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 ("the Fees Regulations"). Therefore, Section 12 (Cost of compliance exceeds appropriate limit) of the FOIA applies, and the FRC is not obliged to comply with your request for information.
In respect of the first part of your request, we have estimated that it will take in excess of 18 hours to conduct searches to establish whether we hold the information requested. This is because third party communications are held by a number of different teams within the FRC and are stored across several different information systems with different searching capabilities.
In respect of the second part of your request, for FRC employees, the information requested may be held in different formats (e.g. on a CV provided by the employee) and we cannot conduct a search using search terms. Consequently, each employee file will need to be considered separately. The FRC currently employs 455 staff. Allowing for 1.5 minutes per file, we estimate it will take approximately 11.25 hours to collect the information requested relating to employees.
In respect of the second part of your request, regarding 'personnel working for, or with, the FRC' who are not FRC employees, we will first have to identify such personnel. This information is not held centrally by the FRC. Therefore, several different FRC teams will each have to identify such personnel and then search their records to establish whether the FRC has a record of those personnel holding a position at PKF. We estimate that this will take a minimum of 6.75 hours.
Accordingly, we estimate for each of your two requests it will take in excess of 18 hours to establish whether we hold the information requested. As this exceeds the costs limit set out in the Fees Regulations we are not obliged to comply with your request for information.
Further information on our refusal to comply with your request is set out in Annex A below.
When we refuse a request because we estimate that the cost limit will be exceeded, we endeavour, where it is reasonable to do so, to provide advice and assistance in respect of how the request could be refined or limited to come within the cost limit.
In respect the first part of your request, it could be refined by requesting information:
- relating to communications with the FRC for a specified purpose and/or a specified team within the FRC;
- from specified third parties;
- regarding fewer individuals and/or entities; and/or
- which is narrower in scope.
Date of response: 23/04/2025
Nature of request: I'd like to ask for information relating to responses to the FRC's ongoing consultation on the UK Stewardship Code. In particular, I'd like information relating to Q2 of the consultation, on the definition of stewardship:
- The number of consultation responses supporting the proposed definition of stewardship;
- The number of consultation responses opposing the proposed definition of stewardship; and
- The number of consultation responses that proposed an alternative definition of stewardship.
If it's possible to break down the responses by category of respondent (e.g. asset managers, asset owners, service providers), I'd be grateful. Please don't include any confidential information - I'm only seeking aggregated data.
Response:
In respect of the second part of your request, it could be refined by requesting information in respect of personnel:
- who have been employed by the FRC within the last five years (or other specified time period);
- specifying personnel by way of reference to their roles, or parts of the FRC within which they work; and/or
- who work with the FRC in a particular capacity.
The FRC would consider any subsequent request afresh, and that consideration would include an assessment of whether any FOIA exemptions may apply to the information sought in any such subsequent request.
In the present circumstances, given the FRC has determined that complying with your request exceeds the applicable cost limits, it has not determined whether any exemptions would apply.
However, we note that in respect of the information you have sought in the second part of your request, if the FRC held the information requested, the FRC would consider whether it is exempt information because it is personal data, in accordance with section 40 of FOIA.
We note your request refers to "Question Two" of the Stewardship Consultation which you state relates to the definition of stewardship. We have understood your request as referring to Question One because Question Two does not relate to the definition of stewardship.
We confirm we hold the information requested.
The consultation responses ("the responses"), apart from those held confidentially, will be published by the FRC together with its feedback statement in the near future. Consequently, we consider that the non-confidential information requested is exempt from disclosure under section 22(1)(a) of FOIA. For a detailed explanation of why the above exemption applies, please see Annex A.
Further, we consider that disclosure of the requested information in the form requested would be likely to prejudice the effective conduct of public affairs. Therefore, we consider that the requested information is exempt from disclosure under section 36(2)(c) FOIA. For a detailed explanation of how this exemption applies, please see Annex A.
Date of response: 11/04/2025
Nature of request: I would like to know more about how UK regulatory bodies are using Generative AI.
Under the Freedom of Information Act 2000 (FOIA), I would like to know the following:
- Are staff within your regulatory body under a general instruction to use AI or Generative AI tools to assist your work?
- Is your regulatory body currently using AI tools or Generative AI tools to assist your work?
- What is your regulatory body's budget for Generative AI tools?
- Can you name the AI tools that your regulatory body uses?
- Does your regulatory body have an AI strategy?
- If your regulatory body does not have an AI strategy, is it planning to have an AI strategy?
Response:
Question 1 Staff within the FRC are not under a general instruction to use AI or Generative AI tools to assist their work. Staff are only authorised to use approved AI or Generative AI tools.
Question 2 Yes.
Question 3 The FRC does not have a dedicated budget for Generative AI tools.
Question 4 We have understood this question as asking us to name any AI tools and/or Generative AI tools that the FRC uses. FRC staff are authorised to use Copilot in Edge and some staff are authorised to use Chat GPT on a testing basis, or for a limited period for a specific purpose, as well as Copilot in Office 365 on a testing basis.
Question 5 and 6 We have responded to these two questions together. The FRC has a Technology Strategy which encompasses a wide scope of technology, including AI. This strategy forms part of Objective 3 in the FRC 3 Year Strategy 2025-2028 and FRC Annual Plan and Budget 2025-2026.
Date of response: 21/03/2025
Nature of request: I am writing to request your assistance in obtaining copies of the following auditing standards issued by the Financial Reporting Council (FRC):
ISA (UK & Ireland) 250A (2004 version) ISA (UK & Ireland) 250A (2009 version)
I have reviewed the information available on the FRC website, specifically at the following link.
While I was able to confirm the availability of ISA (UK) 250A from 2016 onward, I could not locate the older 2004 and 2009 versions. These earlier versions are essential for my research on the historical development of auditing standards, particularly regarding auditors' responsibilities concerning laws and regulations.
If these documents are available, I would be most grateful if you could provide them in PDF format or advise me on how to obtain them. Please let me know if there are any fees associated with this request or if you require further information from my side.
Response:
We confirm the FRC holds the information you have requested.
Please find enclosed the following documents:
a. ISA (UK & Ireland) 250A (2004 version) b. ISA (UK & Ireland) 250A (2009 version)
Date of response: 12/03/2025
Nature of request: I am writing to obtain the following information under the freedom of information act. Please provide the following information for the 2022-23 and 2023-24 financial years:
The total income your organisation received from the government in each year. Your organisation's total expenditure in each year. Your organisation's total staff headcount in each year. The year in which your organisation was originally founded
For the purposes of this FOI, income from the government refers to all income you received from the UK government.. This is most likely in the form of government grants but could also be through other mechanisms. Total expenditure refers to the total amount of money your organisation spent in each financial year. If this is not available, please provide net expenditure and identify it as such.
Your organisation's headcount refers to the total number of staff employed during each financial year. If a total headcount is not available please provide the full-time equivalent figure and identify it as such.
The year in which your organisation was founded refers to the initial founding of the organisation rather than a name change. Please provide the earliest possible date for this.
Response:
The information you have requested is exempt from disclosure under section 21 of FOIA as it is reasonably accessible to you. This is an absolute exemption which means that the public interest does not need to be considered. More details about this exemption are provided in Annex A below.
The information you have requested relating to total government income, total expenditure and staff headcount can be found in the FRC's 2022/23 and 2023/24 Annual Report and Financial Statements, available at the following links:
- Financial Reporting Council Annual Report and Financial Statements 2022/23
- FRC Annual Report and Financial Statements 23-24
The year the FRC was originally founded can be found on Companies House here.
Date of response: 05/02/2025
Nature of request: I am seeking further information on the impact of private equity investment on the audit and accounting profession. Please provide the following:
- copies of any and all analysis the FRC has conducted into the issue.
- copies of any and all meeting minutes between FRC representatives and representatives of private equity firms and trade bodies.
- copies of any and all surveys or similar supervision exercises the FRC has used to gather more information on the market.
Response:
- Copies of any and all analysis the FRC has conducted into the impact of private equity investment on the audit and accounting profession. Please find enclosed the following documents: a. External presentation slides: Tier 1: INE and ANE Online Session on Private Capital Investment, 25 October 2024 (note that these contain information beyond the scope of the request which is provided in case the context is helpful). b. Extracts from an internal presentation: AMS/AFS Liaison meeting on Private Capital Investment, 19 November 2024 (remaining slides are out of scope). c. Extracts from Audit Market Risk Register August 2024 and related slides (remaining information is out of scope).
Some personal data has been redacted in reliance on section 40 FOIA. The FRC holds additional information within the scope of point (1) of your request, which it is withholding pursuant to section 36(2) of FOIA. For a detailed explanation of how this exemption applies, please see Annex A. For completeness, we note that the following letter to audit firms and Recognised Supervisory Bodies dated 26 September 2024 which is published on the FRC’s website may be of interest: FRC Letter: external private capital and audit firms.
We also draw your attention to the research FRC commissioned into barriers to entry and growth faced by audit firms in the UK, which includes research regarding private equity investors:
frc-takes-systemic-look-at-barriers-to-competition-in-uk-audit-market
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Copies of any and all meeting minutes between FRC representatives and representatives of private equity firms and trade bodies. FRC representatives attended a meeting with representatives of a private equity firm on 27 November 2024. The FRC is withholding the notes taken in relation to this meeting pursuant to section 36(2) of FOIA. For a detailed explanation of how this exemption applies, please see Annex A.
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Copies of any and all surveys or similar supervision exercises the FRC has used to gather more information on the market. Please find enclosed: a. A letter to Tier 2 and Tier 3 Audit Firms with the subject "Private Equity investment in the UK Audit Market", dated 8 August 2023. b. Q&As for Audit Registered Firms Contemplating Private Capital (PC) Investment (an internal document which may be used as a starting point to seek information from audit firms which are considering investment from private capital - internal notes have been redacted).
Date of response: 20/01/2025
Nature of request: What is the headcount (number) of staff employed in communications, marketing, press and public affairs in your organisation?
Response:
We confirm the FRC holds the information you have requested. The Stakeholder Engagement and Corporate Affairs Team within the FRC deals with communications, publications, consultations, events and public affairs among other matters. There are 18 employees within this team.
Date of response: 13/01/2025
Nature of request: I would like to see all the information you have from the past six months (from June 1 to the most recent date), excluding news alerts, regarding "Unilever" and "ice cream.
Response:
The FRC may hold the information requested but estimates that establishing whether it holds the information will exceed the cost limit set out in the Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 ("the Fees Regulations"). Therefore, Section 12 (Cost of compliance exceeds appropriate limit) of the FOIA applies and the FRC is not obliged to comply with your request for information.
Date of response: 10/01/2025
Nature of request:
- A table covering the financial years 2019-20 to 2024-25, showing which UK public sector entities had Public Interest Entity (PIE) status in each of those years, together with the rationale for each entity's inclusion.
- A copy of any current published proposals to widen the criteria for being a PIE.
- The statutory and/or regulatory basis for the classification of these UK public sector entities as PIEs.
- A statement of the requirements for the fact of a UK public sector entity having been classified as a PIE to be communicated to the users of its financial statements, including Parliament, citizens and council taxpayers, via the financial statements or audit reports or other means.
Response:
The FRC does not hold the information sought in your first and fourth request. The FRC does not require that information to perform its regulatory functions in relation to public sector entities.
The FRC does not hold the information sought in your second request. You may wish to look at policy papers and consultations published by the Department of Business and Trade that can be found at the following link Policy papers and consultations - GOV.UK.
In response to your third request, the statutory basis for the classification of an entity as a public interest entity arises from the definition of 'public interest entity' in Regulation 2 of the Statutory Auditors and Third Country Auditors Regulations 2016 and Section 494A of the Companies Act 2006.
You may wish to consider making enquiries of the London Stock Exchange, Bank of England and Prudential Regulation Authority in relation to your third request. The London Stock Exchange publishes information in relation to transferable securities. The Bank of England and the Prudential Regulation Authority publish information in respect of banks and insurers.