The TD was recently amended to introduce, among other changes, new country-by-country reporting requirements for issuers who are active in the extractive or logging of primary forest industries.

The Transparency Directive Amending Directive (TDAD) came into force on 26 November 2013. Although each member state has been given 24 months from that date to implement the TDAD, the Treasury has asked the FCA to align the implementation of the TDAD with the implementation by the Department for Business, Innovation & Skills (BIS) of the country-by-country reporting requirements.

On 21 August 2014, the Department for Business, Innovation and Skills (BIS) published a response to its consultation on the implementation of the country-by-country reporting provisions of the EU Accounting Directive in relation to extractive companies, which announced the government’s decision that UK registered companies will be required to complete extractive reports on payments to governments covering financial years beginning on or after 1 January 2015.

At the same time, the government stated its commitment to the early introduction of transparency requirements.

The proposal to implement the TD requirements early will affect relevant issuers where the UK acts as home member state and the FCA’s Disclosure Rules and Transparency Rules (DTRs) apply. It will also affect listed companies and issuers of securitised derivatives who are required by the FCA’s Listing Rules to comply with DTR4.

The proposals set out in the consultation document seek to introduce a new transitional provision applying the new requirements to financial years beginning on or after 1 January 2015 and make consequential amendments to affected DTRs.

The closing date for comment is 7 October 2014.

The consultation document is available at http://www.fca.org.uk/static/documents/consultation-papers/cp14-17.pdf