UK FRC’s Consultation on Auditor Reporting Standards

We refer to the invitation from the Financial Reporting Council (FRC) to comment on proposed revisions to the UK Auditor Reporting Standards (the Standards) We appreciate the opportunity to provide our views on the suggested amendments.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with 19,602 billion Norwegian Kroner (ca GBP 1,410 billion) at 30 June 2025, of which 1,101 billion (ca GBP 79 billion) was invested in the United Kingdom. As a long-term investor, we support well-functioning markets that facilitate the efficient allocation of capital and promote long-term economic growth.

We are active investors in over 65 countries and require reliable, consistent and comparable financial information across global capital markets to support our investment decisions, risk management and stewardship activities. Enhanced auditor reporting directly serves these objectives. In particular, key audit matters provide visibility into the most complex areas of the audit, highlighting risks not apparent from company disclosures alone and enabling better assessment of earnings quality and valuation. We welcome proposals requiring auditors to communicate relevant and entity-specific insights which will support more informed capital allocation.

Given these revisions are directly intended to provide more decision-useful information for investors, we encourage the FRC to complement the revised standards with broader educational outreach on audit reports. Such guidance would help investors fully realise the benefits of enhanced auditor reporting.

We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                    

Jeanne Stampe
Policy Lead