Provision 29: The Board Declaration That Needs Work Now

What Provision 29 Requires

Provision 29 of the 2024 UK Corporate Governance Code asks the board to monitor the company’s risk-management and internal-control framework and, annually, to declare whether it considers the material controls to have been effective. It applies to financial years beginning on or after 1 January 2026, with the first declarations appearing in annual reports published in 2027.

Defining “Material Controls”

The Code deliberately leaves “material controls” for boards to determine — spanning financial, operational, reporting and compliance controls. The work is to identify which controls are material to the business model and strategy, document how they operate, and establish how their effectiveness is evidenced and monitored through the year.

Dry Runs Before Go-Live

Companies that wait until 2027 will be reconstructing a year of evidence retrospectively. A dry run — mapping material controls, testing operating effectiveness and rehearsing the board’s assessment — surfaces gaps while there is still time to remediate. The FRC has signalled it wants concise, outcomes-focused reporting, not boilerplate.