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.’
Cases
CRR Case Summaries and Entity-specific Press Notices (Excel version)
| Entity | UK Oil & Gas Plc (3) |
|---|---|
| Balance Sheet Date | 30 September 2024 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | June 2026 |
| Auditor (5) | PKF Littlejohn LLP |
| Case Summary / Press Notice |
Decommissioning provision In the annual report and accounts for the year ended 30 September 2024, the company used a rate of 16% to discount the decommissioning provision. We asked the company to explain why the rate had increased rather than decreased compared to a discount rate of 10% used in the previous year. The company confirmed that this was an error and a risk-free rate should have been used. The company agreed to restate the comparative figures in its 2025 annual report and accounts and to disclose the fact that this matter had come to its attention as result of the FRC’s enquiries. |
| Entity | UK Oil & Gas Plc (3) |
| Balance Sheet Date | 30 September 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | June 2026 |
| Auditor (5) | PKF Littlejohn LLP |
| Case Summary / Press Notice |
Decommissioning provision We noted an inconsistency between the disclosure in the notes to the accounts and the accounting policy regarding the rate used to discount the decommissioning provision at 30 September 2023. In addition, calculation of the provision was identified as a critical accounting judgement and source of estimation uncertainty yet information about the related key assumptions, sensitivities or a range of reasonably possible outcomes had not been provided. We asked the company to provide details of the calculation of the provision and to clarify the discount rate used. The company provided the information requested and agreed to enhance the disclosure in subsequent annual reports and accounts. We were not persuaded that the discount rate of 10% applied by the company was appropriate as it is generally difficult to justify discounting a provision at a rate that is higher than a risk-free rate. This is because, when discounting liabilities, adjusting for risks that have not been reflected in the cash flows should reduce the risk-free rate. However, the difference between using a discount rate of 10% compared to the corresponding risk-free rate was not considered to be material. We therefore concluded that it would not be proportionate for us to pursue this matter further in respect of the 2023 annual report and accounts but notified the company that we would review this matter in the 2024 annual report and accounts. The results of this review are presented separately in the case summary for the year ended 30 September 2024. Impairment review of oil and gas assets The company disclosed that a discount rate of 2.79% had been used in the impairment review of oil and gas assets for the year ended 30 September 2023. We asked the company to explain how this rate reflected current market assessments of the time value of money and asset specific risks. The company confirmed that no impairment would have been recognised using a higher discount rate but did agree to use a more representative rate in future impairment calculations. Recognition and measurement of convertible loan We asked the company to explain why a convertible loan was recognised in full as a liability rather than as a compound instrument. The company explained that the equity component of the loan was not considered to be material. In addition, the loan was fully repaid during the year ended 30 September 2024. As there were no implications for subsequent annual reports and accounts, we closed our enquiry. Deferred tax on property, plant and equipment We asked the company to explain why deferred tax had not been recognised in respect of property, plant and equipment. The company provided a satisfactory response and agreed to enhance the disclosure in the annual report and accounts for the year ended 30 September 2024. |