UK BIST Consultation on Modernising Corporate Reporting to support long-term economic growth
Letter to United Kingdom Department for Business, Innovation, Science and Trade, 30 September 2026.
We welcome the opportunity to respond to the Department for Business, Innovation, Science and Trade (BIST) 's consultation on Modernising Corporate Reporting to support long-term economic growth.
Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and manages the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As of 30 June 2026, we managed USD 2.29 trillion (GBP 1.73 trillion), of which USD 120.32bn (GBP 90.81 billion) was invested in the United Kingdom (UK), including USD 76.02 billion (GBP 57.4 billion) in the shares of 213 UK companies.
We support the government's objectives and principles for modernising corporate reporting, and in particular the shift towards a principles-based, materiality-driven framework for baseline strategic reporting. Our comments focus on three points. First, materiality should be assessed consistently against the IFRS Conceptual Framework for Financial Reporting (IFRS Conceptual Framework) and UK Sustainability Reporting Standards (UK SRS), with material information, including sustainability-related material information, kept within and connected to the annual report. Second, streamlining should not remove the disclosures and voting rights investors rely on to hold boards to account, such as malus and clawback, directors' shareholdings, responses to shareholder dissent and the annual advisory vote on remuneration. Third, transparency should be maintained where it supports investor confidence, including on distributable reserves and payments to governments in the extractives sector.
Our detailed responses are set out in the annex, grounded in our Global Voting Guidelines and published position papers, and cross-referenced to our prior submissions to other regulators and standard-setters where relevant. We thank the Department for considering our perspective and remain available to discuss any of these points further.
Yours sincerely,
Carine Smith Ihenacho
Chief Governance and Compliance Office
Jeanne Stampe
Lead Policy Advisor