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FOIA Disclosure Log 2026

DISCLOSURE LOG- FOIA Requests

| Date of response | Nature of request # Financial Reporting Council (FRC) Disclosure Log for FOIA Requests

| Date of response | Nature of request | |---|---|---:| | 15/05/2026 | Under the Freedom of Information Act 2000, please provide the following recorded information. From the last 3 financial year's budgeted figures (2022/23, 23/24, 24/25): 1. Climate-related posts a) The number of posts if any (headcount, and FTE where recorded) employed with job titles that include any of the following terms: Climate; Net Zero; Sustainability; Carbon; Emissions; Environmental Sustainability; Climate Change; Climate Action; Climate Policy; Climate Programme; Climate Project; Climate Data; Climate Reporting; Climate Adaptation; Climate Resilience; Energy and Climate; Sustainable Procurement; Green Finance; Green. 2. Cost of those posts The total employment cost for the posts (if any) identified in Question 1, including salary and employer on-costs (e.g. pension and National Insurance), as recorded. 3. External consultants The total amount paid during the same financial year to external consultants, companies, or contractors where the expenditure is recorded under any cost centre, project code, budget line, or purchase description that includes one or more of the following terms: Climate; Net Zero; Sustainability; Carbon; Emissions; Environmental Sustainability; Climate Change; Climate Action; Climate Policy; Climate Programme; Climate Project; Climate Data; Climate Reporting; Climate Adaptation; Climate Resilience; Energy and Climate; Sustainable Procurement; Green Finance; Green. This should include, but not be limited to, expenditure coded to professional services, consultancy, advisory services, or specialist support. If you do not record expenditure in this way, please provide the closest equivalent recorded information held (for example, totals by relevant cost centre or project). If any information requested is not held, please state this clearly. If figures are held only in aggregated form, please provide the aggregated figures. Estimates derived from recorded financial information are acceptable. If complying with this request would exceed the cost limit under Section 12 of the Freedom of Information Act, please disregard point 3. | Our response to each of your questions, using the same headings and numbering as above, is provided below: Climate-related posts 2022/2023 - 0 2023/2024 - 2 2024/2025 - 2 Costs of these posts We consider section 40 (Personal information) of FOIA applies to this information and therefore this information is exempt from disclosure. Further information on the application of this exemption maybe found at Annex A. External Consultants 2022/2023 - £0 2023/2024 - £0 2024/2025 - £0 | |---|---|---| | 21/04/2026 | [Part 1] - General Information: 1a) How many sites are part of this organisation? 1b) Are utilities (gas, electricity, water) procured collectively on behalf of all schools, or by individual academies? 1c) Who is responsible for procurement decisions relating to utilities? (Please state job title) How does the organisation ensure compliance with DfE / ESFA and public procurement regulations when procuring energy? 1d) Does the organisation use a DfE-approved framework for energy procurement? If yes, which one? 1e) Does the organisation have any sustainability or Net Zero objectives that influence procurement decisions? If yes, please summarise. [Part 2] - Energy Procurement & Pricing: 2a) How are your electricity and gas contracts procured? (e.g. direct with supplier, via broker/TPI, via framework) Which framework, DPS, or third-party broker/TPI is or was used? Please state the name. 2b) When was your current electricity contract signed or agreed? 2c) When was your current gas contract signed or agreed? 2d) What is the current contract end date for your electricity supply? 2e) What is the current contract end date for your gas supply? 2f) Who is your current electricity supplier? 2g) Who is your current gas supplier? 2h) If your electricity contract is fixed price, what is the current unit rate (p/kWh)? 2i) If your contract is flexible, half-hourly traded, or index-linked, please just confirm the contract type and we will not ask for a specific rate. 2j) If your gas contract is fixed price, what is the current unit rate (p/kWh)? 2k) If your contract is flexible, half-hourly traded, or index-linked, please just confirm the contract type and we will not ask for a specific rate. 2l) What is the current standing charge (p/day) for electricity and gas? 2m) Was a broker or Third Party Intermediary (TPI) involved in arranging your current contracts? If yes, please state their name. 2n) What commission, broker fee, or TPI payment was paid in connection with your current gas and/or electricity contracts? Please state the amount per meter, per contract, or as a p/kWh uplift. If the organisation does not hold this information, please confirm whether it has been requested from the broker or supplier. 2o) How many suppliers submitted quotations for your most recent electricity and gas procurement? [Part 3] - Metering, MOP, DA & DC Arrangements: 3a) (MOP = Meter Operator I DA = Data Aggregator I DC = Data Collector- these are contracted services that determine how your energy data is captured and settled) Are any of your electricity meters Half-Hourly (HH) settled (Profile Class 00)? 3b) If yes, how many HH meters does the organisation have, and across which sites? 3c) Who is the current Meter Operator (MOP) for your electricity meters? 3d) When was the current MOP contract signed, and what is its end date? 3e) Who is the current Data Collector (DC) and Data Aggregator (DA) for your electricity meters? 3f) What charges are applied for MOP, DA, and DC services? Are these shown as a separate line item on bills, or embedded within the unit rate? 3g) Were MOP, DA, and DC contracts competitively tendered, or were MOP, DA, and DC contracts assigned by the supplier or framework? [Part 4] - Energy Monitoring & Management: 4a) Does the organisation currently have any form of energy monitoring in place? (e.g. AMR, smart meter portal, half-hourly data access, real-time dashboards) If yes, which sites have monitoring, and what type is in place at each? Please distinguish between: real-time I live data I half-hourly/ Day+1 data I monthly smart read only I manual reads only Which platform, portal or software is used to view or analyse energy consumption data? 4b) Is gas consumption monitored separately to electricity? If yes, how? 4c) Does the organisation receive automated alerts for unusual or excessive energy consumption (e.g. overnight or weekend usage)? 4d) Does the organisation receive any bill validation or bill checking service, from a broker, consultant, or software platform? 4e) Has the organisation undertaken any energy audits, Display Energy Certificate (DEC) assessments, or ESOS compliance reporting in the last three years? 4f) Has the organisation ever used energy data to identify and evidence savings? If yes, please give a brief summary. [Part 5] - Water Procurement & Monitoring: 5a) How are your water and wastewater contracts procured? 5b) Which framework, DPS, or third-party was used? Please state the name. 5c) When was your current water contract signed or agreed? 5d) What is the current contract end date for your water supply? 5e) Who is your current water supplier? 5f) What unit rate (p/m3) are you currently paying for water and wastewater, if known? 5g) How many suppliers submitted quotations for your most recent water procurement? 5h) Was a broker or TPI used in procuring your water contract? If yes, please state their name and any fee or commission paid. 5i) Are there any additional services included such as leak detection, water efficiency, or bill validation? If yes, please describe. 5j) Does the organisation have any water monitoring or sub-metering in place to detect leaks or track consumption at site level? | Our response to each of your questions, using the same headings and numbering as above, is provided below: Part 1 - General Information 1a) The organisation consists of two sites. 1b) We do not hold the requested information. Please note that the Financial Reporting Council (FRC) is neither a school nor an academy. 1c) We do not hold the requested information. The FRC does not procure utilities. 1d) No. 1e) No. Part 2 - Energy Procurement & Pricing We do not hold the information requested in this part of your request. Part 3 - Metering, MOP, DA & DC Arrangements We do not hold the information requested in this part of your request. Part 4 - Energy Monitoring & Management Our response to questions 4a), 4c), 4d) 4e) and 4f) in this part of your request is 'no'. We do not hold the information requested by question 4b). Part 5 - Water Procurement & Monitoring We do not hold the information requested in this part of your request. | | 17/04/2026 | For each calendar year from 2020 to 2026 inclusive: 1. The number of cyber security breaches that have being identified that were found to be a result of a malicious threat actor (i.e. not accidental data breach) 2. The breakdown in high-level causes of these breaches as identified by cyber security incident response teams (CSIRTs), for example (but not limited to) unpatched software/hardware, lack of multi-factor authentication (MFA), leaked user credentials, lack of in-transit encryption, etc 3. The number of breaches that occurred that were attributed to a previously known vulnerability to the organisations hardware, software, policies, or processes, for example where system was known to be at risk due to being unpatched or out of support, or security controls were recommended but not enforced, and was defined within the resulting incident response report. 4. The estimated combined costs incurred as a result of cyber security breaches defined in request number one in each year. | |---|---|---| | 23/02/2026 | 1. Does FRC have a duty to investigate complaints submitted by members of the public? 2. How many complaints about the Institute and Faculty of Actuaries (IFOA) (including individual members) has FRC received since 1 July 2025? 2.1 How many of these complaints included "new evidence" which had not previously been seen by FRC? 1.3 How many of these complaints (#2.1) related to dishonest statements issued on behalf of IFOA Council? 2.3 How many of these complaints (#2.2) included evidence showing that the dishonest statements were not disputed by at least two members of IFOA Council? 3. How many of these complaints has FRC discussed with IFoA? 4. How many of these complaints has FRC failed to investigate? | The FRC does not hold the information requested. We confirm that we hold the information requested. We have responded to your questions below using the same numbering as above. 1. The FRC has a published complaints procedure detailing our remit over complaints on the FRC website. This can be found at the following link: Make a complaint. 2. The FRC is responsible for independent supervision of the IFoA and our remit and approach are set out on the FRC website. This can be found at the following link: Supervision of the Actuarial Profession We have received one complaint about the IFoA since 1 July 2025, from yourself. 2.1 This complaint provided information to the FRC in relation to a complaint which had been made in 2023. The FRC formed the view that this information did not amount to new evidence. 2.2 This complaint made an allegation that the IFOA Council had issued a dishonest statement. 2.3 This complaint alleged that members of the IFOA Council had not disputed that the IFOA Council had made the dishonest statement. 3. We have spoken with the IFoA regarding this complaint. 4. After a review of this complaint, we determined that it was a continuation of issues already investigated by the FRC between 2021 and 2023. Due to this, the FRC has not investigated this complaint again and as mentioned in our email to you dated 27 January 2023, your complaint remains closed. | | 13/02/2026 | I am writing to request further information on the Scalebox Programme announced in September. Please provide the following information: 1. The number of firms invited to participate in the programme. 2. The number that have applied to participate, and the number that have been accepted. 3. Copies of any communications sent to firms that have been invited, applied or accepted to the programme. 4. Copies of any FRC meeting minutes or similar discussing the programme. 5. Copies of any assessments of audit price or quality conducted as a result of the programme. 6. The estimated cost of the programme. | Our response to each of your questions is provided below. 1. What are the contractual performance KPI's for this contract? This contract does not include specific contractual Key Performance Indicators. 2. Actual spend on this contract/framework (and any sub lots), from the start of the contract to the current date. £49,200 (inclusive of VAT) 3. Is there an extension clause in the framework(s)/contract(s) and, if so, the duration of the extension? Yes, the contract allows for an extension. It does not specify an extension period. 4. Has a decision been made yet on whether the framework(s)/contract(s) are being either extended or renewed? Yes, the contract will end in 2027. 5. Who is the senior officer (outside of procurement) responsible for this contract? Director of HR, Delivery & Organisational Design be incurred for the 2026 calendar year are approximately £276,000 (estimated total of £330,000). More information on the application of exemptions may be found at Annex A. | | 12/02/2026 | Under the Freedom of Information Act, could I have the following information regarding this consultation please - Audit Enforcement Procedure: Consultation on proposed updates to the FRC's routes to resolution? https://www.frc.org.uk/consultations/audit-enforcement-procedure-consultation-on-proposed-updates-to-the-frcs-routes-to-resolution/ 1. Copies of all the non-confidential responses to the consultation paper. 2. A list of all the organisations/individuals who responded. 3. A list of meetings held with organisations/individuals concerning this consultation and minutes of those meetings. | We confirm that we hold the information requested in relation to all three points of your request. However, we consider the information is exempt from disclosure for the following reasons: - The non-confidential responses to the consultation paper (with personal data removed), including the names of the organisations who provided them, will be published by the FRC on its website. This will take place in the coming months. Under section 22(1)(a) of FOIA, we are not obliged to provide information if the information held is intended for future publication and as such, we consider that the non-confidential responses to the consultation paper, as well as the list of those who provided such responses, are exempt from disclosure. - To the extent that the information specified at 2. and 3. of your request will not be published as described above, we consider that disclosure of this information would be likely to prejudice the effective conduct of public affairs. We therefore consider that this information is exempt from disclosure under section 36(2) (c) of FOIA. - We consider that disclosure of the list of meetings held with organisations/individuals concerning the AEP consultation and any minutes of those meetings (as requested at 3 of your request) would be likely to prejudice the effective conduct of public affairs. We therefore consider that this information is exempt from disclosure under section 36(2)(c) of FOIA. - Personal data is exempt from disclosure. We consider that section 40 of FOIA applies and any personal data within the scope of your request is exempt from disclosure. More information on the application of exemptions may be found at Annex A. Annex A Section 22 of FOIA (Information intended for future publication) Section 22 provides, as relevant: '1) Information is exempt information if –

1. The information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),
2. The information was already held with a view to such publication at the time when the request for information was made, and
3. It is reasonable in all the circumstances that the information should be withheld from disclosure until the date referred to in paragraph (a).'

S22 allows for information to be withheld from disclosure when it is reasonable in all the circumstances to delay the provision of information until it is made generally available through publication. We consider that s22 applies to the non-confidential responses to the consultation, and the list of organisations / individuals who responded on a non-confidential bases sought at 1. and 2. of your request. The FRC will publish its response on the consultation later this year, together with the responses provided on a non-confidential basis and the list of those who provided such responses. This exemption is qualified and we are required by FOIA to balance the public interest for and against disclosure. For disclosure: - There is a general public interest in transparency being demonstrated by releasing the information with this reply. - Disclosure may allow limited public debate and scrutiny of the responses at an earlier stage. - Disclosure may provide the public with limited insight into the FRC's potential approach in relation to proposed changes to the AEP. - There is a clear public interest in the proposed changes to the AEP. - There is a public interest in public bodies providing information they hold that falls within the scope of an FOI request as quickly as possible. Against disclosure: - The FRC will publish the non-confidential responses, and the names of the organisations who responded, in the near future - thereby permitting public scrutiny. The information to be published will be more a comprehensive response which informs the public how the FRC has considered the responses to the consultation. - Refusal of the request will not prevent scrutiny or debate; it will delay it for a short period of time until the FRC's feedback statement and consultation responses are published in accordance with the FRC's established practice. - Publishing the responses on the FRC's website will provide greater transparency than the release of the information requested in isolation. - Given that the information will be made generally available through publication in due course, disclosure at this stage would not be efficient use of FRC resource. Having considered factors for and against disclosure, we have concluded that the balance of the public interest is in favour of maintaining the exemption. Section 36 (Prejudice to the effective conduct of public affairs) S36(2)(c) provides: '(2) Information to which this section applies is exempt information if, in the reasonable opinion of a qualified person, disclosure of the information under this Act- (c) would otherwise prejudice, or would be likely otherwise to prejudice, the effective conduct of public affairs.' In this instance, the FRC's qualified person considers that the disclosure of the list of organisations/individuals who responded to the Consultation (other than those whose responses will be published) and all of the requested information at point 3 of your request would be likely to otherwise prejudice the effective conduct of public affairs. Disclosure of the information now would result in the release of information on the consultation prior to the FRC publishing its response to the Consultation, which would be a departure from the FRC's usual approach to consultations and result in piecemeal release of information which does not reflect the fuller written responses nor the FRC's consideration of those responses. This would be likely to undermine this consultation and future consultation procedures by impacting the FRC's relationship with its stakeholders who would expect the information to be released in the usual manner via the FRC's website. Disclosure would also be likely to reduce stakeholders' willingness to engage in future consultation meetings and roundtables, thereby having a negative impact on future consultation processes. S36 is qualified and we are required by FOIA to balance the public interest for and against disclosure. For disclosure - There is a general public interest in transparency being demonstrated by releasing the information with this reply. - Disclosure may allow limited public debate and scrutiny of matters discussed at meetings held in relation to the Consultation. - Disclosure may provide the public with limited insight into the FRC's potential approach in relation to proposed changes to the AEP. - There is a public interest in the proposed changes to the AEP. - There is a public interest in public bodies providing information they hold that falls within the scope of an FOIA request as quickly as possible. Against disclosure - The FRC will publish its response to the consultation responses and those written responses which are not confidential, thereby permitting public scrutiny and giving insight into the FRC's policy analysis and the consultation responses. The information intended to be published will provide significantly more detail and context than the requested information. - Publication of the FRC's response to the Consultation and non-confidential responses will occur later this year. Refusal of the request will not prevent scrutiny or debate and occurs with the benefit of the FRC's feedback of the responses received. - It is in the public interest for the FRC to benefit from the full range of views of stakeholders when preparing responses to consultations, in order that their consultation responses properly and fully take account of those views. To obtain such views, stakeholders need to be confident in taking part and putting forward all of their views, including potentially controversial positions, without fear of their words being published. Disclosing the requested information would be likely to deter stakeholders from taking part in roundtable events of meetings at all, and to be less likely to share frankly and candidly their full range of views. - A regulator's effectiveness is prejudiced when trust in that body is damaged. Trust may be damaged, in circumstances where the FRC publishes a discussion that stakeholders participating in the discussion did not expect would be made public. - Provision of the requested information will pull focus and potentially resources from the policy development of the AEP to the management of the consequences of the disclosure (e.g. stakeholder and media management). - Provision of the requested information is likely to provide minimal information which might not reflect the fuller written consultation responses of the attendees. Having considered factors for and against disclosure, we have concluded that the balance of the public interest is in favour of maintaining the exemption. Section 40 (Personal data) S 40(2) of the FOIA provides an exemption from the right to information if it is personal data, as defined in the Data Protection Act 2018. This is an 'absolute' exemption. Therefore, it is not necessary to balance the public interest for and against disclosing the information. We consider that the first condition (as stated in s40(3A) of FOIA) is satisfied, as the information requested comprises the personal data of individuals other than yourself and which, if disclosed, would breach the requirement of the UK General Data Protection Regulations ("UK GDPR") including the data protection principles of Article 5 and the Data Protection Act 2018 ("DPA"). In particular, it would be a breach of the first data protection Principle as set out in Article 5 of the UK GDPR, to disclose some information as it would not be necessary or fair to the individuals concerned, or lawful, where none of the conditions in Article 6(1) of the UK GDPR have been met. The individuals concerned have not provided their consent for their personal details to be made public and the release of such information may be detrimental to the individuals themselves. Consequently, for these reasons we have withheld all personal data contained within the consultation responses, list of individuals/organisations who responded and in any meeting notes under s 40 of FOIA. | | 14/01/2026 | Any contracts between your organisation and Montfort Communications Limited from 1st July 2019 to the present. Copies of any emails between the FRC's Director of Stakeholder Engagement & Corporate Affairs and Montfort Communication during 2023 and 2024. | The FRC holds the information you have requested. We address each limb of your request separately below. Request for contracts between Montfort Communications Limited (Montfort) and the FRC The information within the scope of your request and to which the FRC does not consider an exemption applies is attached at Annex C. We are withholding information that falls within the scope of this aspect of your request where we consider one or more of the following exemptions applies: - Section 40 of FOIA: some of the information requested constitutes personal data and is exempt from disclosure under section 40 of FOIA because its disclosure would breach data protection law. - Section 43 of FOIA: some of the information requested, if disclosed, would be likely to prejudice both the FRC and Montfort's commercial interests. - Section 36(2)(b)(ii) of FOIA: some of the information requested, if disclosed, would be likely to inhibit the free and frank exchange of views for the purposes of deliberation. Emails between the FRC's Director of Stakeholder Engagement & Corporate Affairs and Montfort The information within the scope of this aspect of your request, and to which the FRC does not consider an exemption applies, is appended at Annex D. We are withholding information that falls within the scope of your request where we consider one or more of the following exemptions applies: - Section 40 of FOIA: some of the information requested constitutes personal data and is exempt from disclosure under section 40 of FOIA, because its disclosure would breach data protection law. - Section 43 of FOIA: some of the information requested, would, or would be likely to, prejudice both the FRC and Montfort's commercial interests if disclosed. - Section 36(2)(b)(i) of FOIA: some of the information requested would, or would be likely to, inhibit the free and frank provision of advice if disclosed. - Section 36(2)(b)(ii) of FOIA: some of the information requested, if disclosed, would, or would be likely to, inhibit the free and frank exchange of views for the purposes of deliberation. - Section 36(2)(c) of FOIA: some of the information requested, if disclosed, would, or would be likely to prejudice, the effective conduct of public affairs. |

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Name FOIA Disclosure Log 2026

Publication date 18 May 2026

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