CRR Case Summaries and Entity-specific Press Notices
The FRC publishes, on a quarterly basis, summaries of its findings from recently closed reviews that resulted in a substantive question to a company (‘Case Summaries’). In addition, it publishes the names of companies whose reviews were closed in the previous quarter without the need for a substantive question. No Case Summary is prepared for such reviews.
Case Summaries, which are available for cases closed in the quarter ending March 2021 onwards, are included in the table below. As, currently, the FRC is subject to existing legal restrictions on disclosing confidential information received from a company, the Case Summaries can only be disclosed with the company's consent. Where consent has been withheld by the company, that fact is disclosed in the table.
From March 2018 until March 2021, the FRC published the names of companies whose reviews were closed in the previous quarter but did not prepare Case Summaries. However, on an exceptional basis, specific cases may be publicised through entity-specific Press Notices, which can also be found in the table below.
The FRC’s reviews are based solely on the company’s annual report and accounts (or interim reports) and do not benefit from detailed knowledge of the company’s business or an understanding of the underlying transactions entered into. They are, however, conducted by staff of the FRC who have an understanding of the relevant legal and accounting framework. The FRC’s correspondence with the company provides no assurance that the annual report and accounts (or interim reports) are correct in all material respects; the FRC’s role is not to verify the information provided but to consider compliance with reporting requirements. The FRC’s correspondence is written on the basis that the FRC (which includes the FRC’s officers, employees and agents) accepts no liability for reliance on its letters or Case Summaries by the company or any third party, including but not limited to investors and shareholders.
Key
- Only a certain number of CRR’s reviews result in substantive questioning of the Board. Matters raised may cover questions of recognition, measurement and/or disclosure.
- CRR’s routine reviews of companies’ annual reports and accounts generally cover all parts over which the FRC has statutory powers (that is, strategic reports, directors’ reports and financial statements). Similarly, CRR’s routine reviews of companies’ interim reports will generally cover all information in that document. Limited scope reviews arise for a number of reasons, including those conducted when a company’s annual report and accounts or interim report are selected for thematic review or reviews that have been prompted by a complaint. In accordance with the FRC's Operating Procedures, for Corporate Reporting Review, CRR does not identify those companies whose reviews were prompted by a complaint.
- The FRC may ask a company to refer to its exchanges with CRR when the company makes a change to a significant aspect of its annual report and accounts or interim report in response to a review.
- Case closed after 1 January 2021 but performed under operating procedures that did not allow for the publication of Case Summaries.
- From the quarter ended June 2023, the FRC started identifying the auditor of the annual report and accounts, or the audit firm that issued a review report on the interim report, that was the subject of the CRR review. This information was also back-dated for closed cases publicised from the quarter ended September 2022. Cases marked N/A relate to those published prior to September 2022 or interim reviews that did not have a review opinion.’
Case Summaries
CRR Case Summaries and Entity-specific Press Notices (Excel version)
| Entity | Card Factory plc (3) |
|---|---|
| Balance Sheet Date | 31 January 2025 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2026 |
| Auditor (5) | Forvis Mazars LLP |
| Case Summary / Press Notice |
We queried why a cash flow in respect of dividend payments was classified within investing activities in the parent company cash flow statement. The company acknowledged that the amount should have been included within financing activities and agreed to revise the presentation and restate comparative figures in its 2026 annual report and accounts. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. |
| Entity | Headlam Group plc (3) |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2026 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
Impairment testing of cash generating units (CGUs) and investments in subsidiaries We asked the company to explain its approach to testing CGUs and investments for impairment, including assumptions relating to growth rates. The company provided a satisfactory response and agreed to improve disclosures relating to growth rate assumptions in the estimation of the value in use of the Melrose CGU. Presentation of cash and cash equivalents net of overdrafts We sought clarification of the basis on which the consolidated accounts presented a cash and cash equivalents balance which appeared to result from offsetting cash and overdraft positions in a cash pooling arrangement. The company explained this represented the balance on a single bank account in which multiple group companies participate with joint and several liability, rather than a pooling arrangement, and agreed to correct its disclosures regarding this arrangement. In the light of this explanation, we questioned why the parent company accounts recognised a larger cash and cash equivalents balance than the group accounts. The company agreed to restate the parent company amount to reflect the balance on the single bank account, with a corresponding adjustment to intercompany receivables, and to update its accounting policy disclosures to explain how it accounts for a single bank account in which multiple group companies participate. As the restatement affected a primary financial statement of the parent company, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. |
| Entity | STV Group plc (3) |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2026 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
Statement of cash flows We asked the company to explain the basis for classifying the purchase of additional shares in subsidiary undertakings as a cash flow from investing activities in the consolidated statement of cash flows as this classification appeared inconsistent with the requirements of IAS 7, ‘Statement of Cash Flows’. The company agreed that this payment should have been classified as a financing activity in the cash flow statement and to restate the comparatives in its next report and accounts. There was no impact on net cash flows for the period. As this related to a primary statement, we asked the company to disclose that the matter had come to its attention as a result of our enquiry. |
| Entity | The Law Debenture Corporation p.l.c. (3) |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2026 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
Dividend liability We asked the company to explain the basis for recognising a liability for an interim dividend which had not been paid until after the year end. The company acknowledged that recognising a liability was inconsistent with its accounting policy and agreed to restate the 31 December 2024 position in its next report and accounts. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. |
| Entity | Vanquis Banking Group plc (3) |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2026 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
Finance income presented in the statement of cash flows We asked the company for an explanation of the finance income received disclosed in the statement of cash flows. We closed our enquiry after the company agreed to present cash flows from interest received and interest paid separately in its cash flow statement in the 2025 annual report and accounts, including a restatement of the comparative figures. Internally generated intangible assets in the statement of cash flows We asked the company to explain the basis for presenting internally generated intangible assets as a non-cash adjustment in operating activities, rather than an outflow in investing activities, in the statement of cash flows. The company explained that the amount should have been reported within investing activities and agreed to restate the comparative cash flow statement in the 2025 annual report and accounts. Since these restatements affect a primary financial statement, the company agreed to disclose in its 2025 annual report and accounts the fact that the matters had come to its attention as a result of our enquiry. Accounting for Post‑charge‑off assets (PCOA) We asked the company for additional information on the initial and subsequent measurement of PCOA at amortised cost, given the expectation of sale. We closed our enquiry after the company provided satisfactory information. Release of expected credit loss (ECL) provisions to profit or loss We sought an explanation of the basis and approach for the release of ECL provisions to profit or loss when accounts are charged off. The company provided a satisfactory explanation and agreed to clarify its disclosure in the 2025 annual report and accounts. Definition of default We asked the company to clarify its revisions to the definition of default and the impact these had on ECL staging. The company provided a satisfactory explanation and agreed to enhance its disclosure in relation to any future changes to the definition of default. Impairment testing of investment in subsidiaries We asked the company for additional information on the impairment testing of investment in subsidiaries. We were satisfied with the company’s explanation. ECL allowance on amounts owed by group undertakings We asked the company to explain the key assumptions and estimates for its ECL measurement relating to amounts owed by group undertakings, including the assessment of significant increase in credit risk. We closed our enquiry after the company provided a satisfactory response and agreed to enhance its disclosures in this regard in the 2025 accounts. |
| Entity | Carclo Plc (3) |
| Balance Sheet Date | 31 March 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Forvis Mazars LLP |
| Case Summary / Press Notice |
Offsetting of bank overdraft We questioned why the company presented its multi-party, multi-currency overdraft facility net of its positive cash balances in its consolidated statement of financial position for the year ended 31 March 2024. Following a review of the arrangement, the company concluded that, although there is a legal right of offset, there was no physical transfer of cash either during the year or at the reporting date, and the individual accounts continued to be used during the normal course of business. As a result, the intent to settle net condition for offsetting in IAS 32, ‘Financial Instruments: Presentation’, was not met. The company agreed to restate the 31 March 2024 comparatives in its 2025 accounts, presenting the balances on a gross basis. The company also confirmed its intent to disclose that the matter had come to its attention as a result of our enquiry. |
| Entity | European Assets Trust PLC (3) |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
We asked the company to explain why the currency translation adjustments for the year were recognised directly in equity, rather than in other comprehensive income. The company acknowledged that the translation adjustments should have been recognised in other comprehensive income and agreed to present a Statement of Other Comprehensive Income in future reports and accounts. As the restatement affected a primary statement, we asked the company to disclose that the matter had come to its attention as a result of our enquiry. |
| Entity | Great Southern Copper plc (3) |
| Balance Sheet Date | 31 March 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | PKF Littlejohn LLP |
| Case Summary / Press Notice |
Parent company statement of cash flows We asked the company to explain the basis for presenting cash flows relating to long-term loans to its subsidiary as operating activities in the parent company’s statement of cash flows. The company acknowledged that these cash flows should have been presented as investing activities and agreed to restate the comparative amounts in its 2025 annual report and accounts. As the change affected a primary statement, we asked the company to disclose that the matter had come to its attention as a result of our enquiry. |
| Entity | Hummingbird Resources Plc (3) |
| Balance Sheet Date | 31 December 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | RSM UK Audit LLP |
| Case Summary / Press Notice |
Capitalisation of revenue and costs for the Kouroussa gold mine We queried why revenue and costs relating to the Kouroussa gold mine were capitalised, rather than recognised in profit or loss. These amounts appeared to represent both the proceeds from selling gold, and the costs of producing it, while bringing the mining asset to the location and condition necessary for it to be capable of operating in the manner intended by management. Such proceeds and costs are required to be recognised in profit or loss under IAS 16, ‘Property, Plant and Equipment’. The company acknowledged that the amounts should be recognised in profit or loss and agreed to restate the comparative figures in its 2024 annual report and accounts. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. Pasofino acquisition We sought clarification of the accounting treatment applied to the Pasofino acquisition in the parent company and consolidated accounts. The company provided sufficient additional detail about the transaction to satisfy our enquiries. VAT and other amounts receivable from the Governments of Mali and Guinea In respect of VAT receivable, we requested further information about how the company determined that the amount was recoverable and the expected timing of recovery. The company gave a satisfactory response and agreed to provide additional information about the expected timing of recovery of the balance in its 2024 annual report and accounts. In respect of other amounts receivable, we requested more details about how the consideration of multiple scenarios had been incorporated into the determination of the expected credit loss for this receivable and how the directors satisfied themselves that the net carrying amount was recoverable. The company satisfactorily responded to our enquiries. Statement of cash flows We asked the company to explain a difference between the additions to property, plant and equipment in the year and the related investing cash outflow reported in the consolidated statement of cash flows. The company provided a satisfactory response. We also asked the company to explain how the opening and closing balance sheet positions for receivables from subsidiaries reconciled to the ‘increase in amounts lent to subsidiaries’ cash outflow shown within investing activities in the parent company statement of cash flows. The company satisfactorily responded to our enquiry. |
| Entity | Kelda Eurobond Co Limited (3) |
| Balance Sheet Date | 31 March 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
Consolidated statement of cash flows We asked the company to explain inconsistencies between its cash flow statement and the notes to the financial statements. The company agreed to restate amounts relating to interest paid, repayment of loans, borrowings raised and repaid, issuance of shares and payments on derivatives. The company also agreed to disaggregate its cash flow on purchases of intangible assets from that on purchases of property, plant and equipment, and to correct disclosure in the notes relating to cash flow movements on financing liabilities. Impairment losses from financial assets We sought clarification of the company’s approach to estimating expected credit losses on trade receivables and of its disclosure of the impairment loss from those assets. The company provided a satisfactory response, and agreed both to restate its income statement to present the impairment loss as a separate line item and to correct disclosure in the notes. As the changes affected two primary financial statements, we asked the company to disclose the fact that the matters had come to its attention as a result of our enquiry. |
| Entity | Thames Water Utilities Limited (3) |
| Balance Sheet Date | 31 March 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
Revenue recognition in respect of Thames Tideway Tunnel (TTT) charges We asked the company to give a more detailed explanation of its accounting policy for recognising revenue relating to amounts received from TTT charges. The company provided a satisfactory response and confirmed that it considered the profits arising from TTT charges to be unrealised. The company agreed to enhance its future disclosures, to explain further the reasoning for revenue in respect of TTT charges being recognised in the current period, and to clarify the distinction between water and wastewater charges (within which TTT charges are billed) and infrastructure charges. Capitalisation of impairment loss on property We sought clarification of the treatment of an impairment loss on property, which had been capitalised into the cost of infrastructure assets under construction. The company agreed to enhance its disclosures relating to land and buildings purchased to facilitate the construction of the wider TTT asset and costs capitalised into the cost of construction. We observed that, where a decline in value arises from consuming the economic benefits of the property through its intended use, it is likely to represent depreciation, under the cost model in IAS 16, ‘Property, Plant and Equipment’, rather than impairment. We encouraged the company to review its accounting policy for these assets, to ensure that depreciation is recognised on a systematic basis by reference to the pattern of consumption. Cash flow statement presentation of dividends and payment for surrender of tax losses We enquired about the company’s presentation of an operating cash inflow for group relief and a financing cash outflow for a dividend, in the light of disclosure indicating that these amounts had been settled without the use of cash or cash equivalents. The company explained how it had entered into a settlement deed with other group companies, and that additional disclosures had been provided in the notes enabling users to understand the nature of the transactions. Having considered the company’s explanation, we did not agree that the arrangement provided sufficient grounds for presenting these transactions in the cash flow statement, because there was no actual movement of cash or cash equivalents. The company agreed to restate the comparative figures in its 2024/25 statement of cash flows, to exclude the non-cash amounts. In disclosing the restatement, the company noted that the matter had come to its attention as a result of our enquiry. |
| Entity | Vedanta Resources Limited (3) |
| Balance Sheet Date | 31 March 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | MacIntyre Hudson |
| Case Summary / Press Notice |
Athena Chhattisgarh Power Limited (ACPL) We sought clarification of the accounting treatment applied to the acquisition of ACPL in the parent company and consolidated annual report and accounts, including the rationale for the prior year restatement in the consolidated annual report and accounts and the basis on which group tax balances were affected. The company provided a satisfactory explanation and confirmed that the accounting treatment applied did not result in a departure from IFRSs. Rajasthan production sharing contract (PSC) The company recognised revenue relating to the outcome of a tribunal concerning the Rajasthan PSC. We asked the company to explain how the revenue recognised reconciled to the related movements in balances owed to and from the Government of India and the joint operation partner. The company provided a satisfactory response. Sale of a non-controlling interest in a subsidiary We queried why a cash flow arising from the sale of a non-controlling interest was classified within investing activities, rather than within financing activities as required by IAS 7, ‘Statement of Cash Flows’. The company acknowledged that the amount should have been included within financing activities and agreed to revise the presentation and restate comparative figures in its 2025 annual report and accounts. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. We also asked the company to explain how a balance included in the cash flow statement for proceeds from sale of subsidiaries related to corresponding amounts recognised in the statement of changes in equity. The company provided us with a satisfactory explanation, including a reconciliation of the amounts |
| Entity | Central Asia Metals plc (3) |
| Balance Sheet Date | 31 December 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | June 2025 |
| Auditor (5) | BDO LLP |
| Case Summary / Press Notice |
Silver streaming arrangement We questioned why silver purchases made in relation to a silver streaming arrangement were presented as a reduction in revenue rather than a cost of sale. As a result of our further inquiries, the company reconsidered its presentation and agreed to reclassify the silver purchases from revenue to cost of sales, and to restate the 2023 comparative amounts in the 2024 annual report and accounts. As the reclassification affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. We asked how a statement referring to satisfying the silver streaming arrangement through own production related to the silver purchases referred to above. We also sought further explanation to support the company’s conclusion that the silver streaming agreement should not be accounted for as a derivative. The company explained its conclusion that the silver streaming arrangement meets the criteria for the ‘own use’ exemption to financial instrument accounting. The company agreed to enhance the disclosures around the silver streaming arrangement, including the basis on which it is fulfilled through third party purchases, and the significant judgements disclosure about the ’own use’ exemption in its 2024 annual report and accounts. Share-based payments’ classification We asked the company to clarify the basis for its conclusion that its share-based payment arrangements should be accounted for as equity-settled, in the light of recent cash settlements. After further inquiries, the company agreed to account for share-based payments as cash-settled from 1 January 2023, which the company considers to be the date at which it established a practice of cash settlement. It agreed to restate the 2023 comparative amounts in the 2024 annual report and accounts accordingly. As this change also affected the primary statements, we asked the company to disclose the fact that this matter had also come to its attention as a result of our enquiry. Earnings per share We requested further information about the calculation of the weighted average number of shares used to calculate basic and diluted EPS, and whether this was adjusted for shares held in an employee benefit trust (‘EBT’). We also observed an apparent inconsistency in the number of share options adjusted in the diluted EPS calculation. The company agreed to adjust the number of shares used to calculate basic EPS for shares held in the EBT. It will do this prospectively as it concluded the effect on comparative amounts was not material. The company satisfactorily explained the reason for the apparent inconsistency in the number of share options adjusted in the diluted EPS calculation. |
| Entity | Chapel Down Group PLC (3) |
| Balance Sheet Date | 31 December 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | June 2025 |
| Auditor (5) | Crowe U.K. LLP |
| Case Summary / Press Notice |
Deferred tax in respect of share-based payments We asked the company to explain the basis on which the deferred tax on share-based payments had been calculated and presented. The company confirmed that the deferred tax credit in respect of share-based payments should have been directly recognised in equity rather than as a component of other comprehensive income. The company agreed to restate the 2023 comparative amounts in its 2024 report and accounts to reflect this, and to disclose the fact that the matter had come to its attention as a result of our enquiry. Alternative performance measures We asked the company to explain how adjusted EBITDA reconciled to the equivalent IFRS measure in the accounts, and to explain the rationale for the treatment of depreciation in determining adjusted EBITDA. The company responded satisfactorily and agreed to expand its future disclosures in this area. |
| Entity | Drilton Limited (3) |
| Balance Sheet Date | 31 December 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | June 2025 |
| Auditor (5) | RSM UK Audit LLP |
| Case Summary / Press Notice |
Consolidated statement of cash flows We questioned the treatment of term deposits, loans granted to joint ventures and purchases of tangible assets in the company’s cash flow statement. As a result, the company agreed to make the following changes in its next annual report and accounts: To restate term deposits as cash equivalents; to restate the cash flows to the joint venture from operating to investing activities; and to include additional disclosure in its future annual report and accounts should the difference between fixed asset additions and the associated investing cash flows be considered material. Future contract losses We challenged the company’s recognition of future contract losses within both accruals and deferred income, and as a deduction to amounts recoverable on contracts. The company acknowledged that this treatment was inconsistent but explained that the contract losses deducted from amounts recoverable on contracts was immaterial. The company agreed to amend its accounting policy and to consistently disclose contract losses as provisions in its future annual report and accounts. The company also identified a number of other balances that had been misclassified as accruals and agreed to restate these, and the future contract losses, as provisions in its 2024 accounts. As the above restatements affected the primary statements, we asked the company to disclose the fact that the matters had come to its attention as result of our enquiries |