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

  1. 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.
  2. 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 Supervision Committee’s Operating Procedures, CRR does not identify those companies whose reviews were prompted by a complaint.
  3. 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.
  4. Case closed after 1 January 2021 but performed under operating procedures that did not allow for the publication of Case Summaries.
  5. 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)

1238 case summaries
Entity Rio Tinto plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) KPMG LLP
Case Summary / Press Notice N/A
Entity Rolls-Royce Holdings plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity Rotork Plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published December 2022
Auditor (5) Deloitte LLP
Case Summary / Press Notice N/A
Entity Sanne Group plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity ScS Group plc (3)
Balance Sheet Date 31 July 2021
Exchange of Substantive Letters (1) Yes
Scope of Review (2) Full
Quarter Published December 2022
Auditor (5) N/A
Case Summary / Press Notice

Product warranty sales

We questioned the basis for recognising revenue from the sale of product warranties as principal. As a result of our enquiry, the company reconsidered the principal versus agent requirements in IFRS 15 ‘Revenue from Contracts with Customers’ and reviewed the accounting treatment adopted by its peers. The company concluded that it did not control product warranties before transferring them to the customer and that revenue related to the sale of these warranties should have been recognised as agent rather than as principal.

Consequently, the company agreed to restate the comparative amounts in the following year’s income statement. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as result of our enquiry.

The company also agreed to make certain improvements to its accounting policy for product warranty sales and enhance certain other revenue-related disclosures.

Product guarantees

We asked the company to explain the accounting treatment of its 12-month and 20-year product guarantees. The company satisfactorily responded to our query.

Entity Shell plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) Ernst & Young LLP
Case Summary / Press Notice N/A
Entity Smith and Nephew plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) KPMG LLP
Case Summary / Press Notice N/A
Entity Smurfit Kappa Group plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) KPMG Ireland
Case Summary / Press Notice N/A
Entity Spirent Communications plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) Yes
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) Deloitte LLP
Case Summary / Press Notice

This company was selected as part of our thematic review of deferred tax assets and, as such, only these disclosures were reviewed.

Non-recognition of UK deferred tax assets

We asked the company to explain the extent to which it had considered the requirement of IAS 12, ‘Income Taxes’, to recognise deferred tax assets in relation to unused tax losses to the extent that there are sufficient taxable temporary differences relating to the same taxation authority and the same taxable entity.

The company satisfactorily explained that the unrecognised deferred tax assets in the UK relate to non-trading losses that are recoverable only against future non-trading profits, and agreed to clarify this in its future reporting. 

Reconciling items in the effective tax rate reconciliation

We requested more information on the nature of reconciling items in the effective tax reconciliation related to the recognition and utilisation of temporary differences previously not recognised, and sought confirmation that deferred tax assets are recognised to the extent that their recovery is considered probable.

The company explained the components of the reconciling items, and the circumstances that led to their recognition in the respective periods.  The company explained that it would recognise in its next annual report and accounts the full amount of an immaterial deferred tax asset not previously recognised for which recovery is considered probable, and agreed to consider whether to provide additional explanations of such reconciling items to aid the reader in future reporting periods.

Entity Sthree plc
Balance Sheet Date 30 November 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity St James’s Place plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity STV Group plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity Taylor Wimpey plc
Balance Sheet Date 31 December 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Full
Quarter Published December 2022
Auditor (5) PricewaterhouseCoopers LLP
Case Summary / Press Notice N/A
Entity Ted Baker plc
Balance Sheet Date 30 January 2022
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) BDO LLP
Case Summary / Press Notice N/A
Entity The Bankers Investment Trust PLC
Balance Sheet Date 31 October 2021
Exchange of Substantive Letters (1) No
Scope of Review (2) Limited
Quarter Published December 2022
Auditor (5) Ernst & Young LLP
Case Summary / Press Notice N/A