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 | 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 | Frasers Group Plc |
| Balance Sheet Date | 28 April 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | September 2025 |
| Auditor (5) | RSM UK Audit LLP |
| Case Summary / Press Notice | Consent withheld |
| Entity | FW Thorpe Plc |
| Balance Sheet Date | 30 June 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
Obligations to purchase non-controlling interests (NCI) We asked for explanations about the nature of arrangements with NCI and the accounting treatment applied by classifying NCI as financial liabilities measured at fair value through profit or loss. The company provided a satisfactory explanation and agreed to enhance the NCI accounting policy disclosures to clarify its accounting approach in its next annual report and accounts. Reclassification of comparative cash flows We asked the company to explain the basis for restating its comparative cash flow statement to classify payments relating to obligations to purchase shares in a subsidiary as cash flows from financing activities. We closed our enquiries after it explained the rationale for the restatement, together with the judgements applied. Defined benefit pension scheme We asked for further information to help us understand the future expected contributions to the defined benefit pension scheme and the accounting treatment applied to the additional liability. We were satisfied with the company’s explanations and its agreement to present the additional funding liability as a pension liability in its next annual report and accounts. |
| 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 | Hercules plc |
| Balance Sheet Date | 30 September 2024 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | CLA Evelyn Partners Limited |
| Case Summary / Press Notice | N/A |
| Entity | H&M Hennes & Mauritz UK Limited |
| Balance Sheet Date | 30 November 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
Summary of findings Bad debt provision We asked for information to help us understand whether an additional bad debt provision of £3.5 million identified after the year-end had been treated as an adjusting or non-adjusting post-balance sheet event. We closed our inquiry after the company explained that the provision was an adjusting post-balance sheet event and was included in its balance sheet at 30 November 2023. Customer loyalty scheme We asked the company to explain its accounting policy which stated that material rights arising from a customer loyalty scheme were recognised by crediting cost of sales, rather than deferring revenue on the balance sheet. The company explained that the accounting policy was inaccurate, and agreed to amend the disclosure in its 2024 annual report and accounts. |
| Entity | HSBC Holdings Plc |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice | N/A |
| 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 | IMI Plc |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice | N/A |
| Entity | Inchcape plc |
| Balance Sheet Date | 31 December 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
FCA review into motor finance commission arrangements The annual report referred to a potential exposure to the FCA review into motor finance commission arrangements arising from the terms of an indemnity given to the buyer of its UK business. We asked the company about the extent of the group’s exposure to this matter. The company provided a satisfactory response to our questions and we encouraged the company to provide any information about the range of reasonably possible outcomes, to the extent this is quantifiable, in future reports. Distributable profits and distributions We observed that the company had paid interim dividends and purchased its own shares in the year ended 31 December 2024. However, the parent company’s 2023 accounts showed insufficient retained profits to cover these transactions, and no interim accounts had been filed at Companies House to support them, as required by section 836(2)(a) of the Companies Act 2006 (the Act). The company confirmed that there were sufficient distributable reserves, as shown in the individual company accounts as at 31 December 2023, to support the payment of the interim dividends. The directors were also satisfied that there were sufficient reserves prior to the share repurchase, but acknowledged that they had not filed the relevant accounts at the required time. The company explained the steps that it intends to take to rectify its non-compliance with the requirements of the Act. |
| Entity | IntegraFinHoldings Plc |
| Balance Sheet Date | 30 September 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Ernst & Young LLP |
| Case Summary / Press Notice |
Impairment testing The company used a discount rate of 14.4% in calculating the recoverable amount of the T4A cash-generating unit (CGU) for the purpose of the goodwill impairment assessment within the consolidated accounts. We asked the company to explain why a different discount rate of 17% was used in the parent company accounts. The company explained that the impact of the different rates on the consolidated accounts had been assessed, and was below the materiality threshold and, consequently, we did not pursue the matter further. We asked the company to clarify whether the sensitivity in respect of the CURO licence users is intended to reflect the impact of a 2.3% absolute (as opposed to relative) change in the annual growth rate. The company confirmed that this was an absolute change. In addition, we asked the company to clarify the amount by which the T4A discount rate, and the annual growth rate of CURO licence users, would each need to change in order for the recoverable amount of the CGU to equal its carrying value, and the sensitivity of the goodwill impairment assessment to changes in expense inflation. The company provided the information requested. We closed our enquiry but reminded the company of the specific accounting requirement to disclose this information in certain circumstances. |
| 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 | Kitwave Group plc |
| Balance Sheet Date | 31 October 2024 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | Grant Thornton UK LLP |
| Case Summary / Press Notice | N/A |
| Entity | Kodal Minerals Plc |
| Balance Sheet Date | 31 March 2024 |
| 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 |
Gain on partial disposal of a subsidiary We asked for further information about the basis on which the gain on partial disposal of Kodal Mining UK Limited (KMUK), a subsidiary, was calculated. The company provided a satisfactory response. In closing the matter, we highlighted ways in which future disclosures in this area could be enhanced. Discontinued operations We sought to understand the basis on which the partial disposal of KMUK failed to meet the IFRS 5 ‘Non-current Assets Held for Sale and Discontinued Operations’ definition of a discontinued operation. The company provided a satisfactory response. In closing the matter, we observed that it would be helpful if the company presented, in future accounts, disclosures explaining why the partial disposal of KMUK did not meet the definition of a discontinued operation. |
| Entity | Learning Technologies Group Limited |
| Balance Sheet Date | 31 December 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2025 |
| Auditor (5) | BDO LLP |
| Case Summary / Press Notice |
Presentation and disclosure of contract liabilities, contract assets and receivables We asked the company to explain references to net presentation of contract liabilities, to present disclosures relating to its remaining performance obligations, and to provide an analysis of its contract liabilities. The company agreed to clarify the language used to disclose the amount of consideration invoiced in advance of performance but not yet due, and which consequently had not been recognised, despite use of terminology which suggested that this may have been netted off other amounts. The company also acknowledged that the exemption in paragraph 121 of IFRS 15, ‘Revenue from Contracts with Customers’, had been erroneously applied to its remaining performance obligations under fixed-price contracts, and agreed to disclose the relevant information in its future annual reports and accounts. |