Reporting on COVID-19

Many of our clients are asking us how they should communicate and report on COVID-19.

A key starting point is to focus on what investors need to know during this time of significant uncertainty, and to that end the Financial Reporting Council’s (FRC’s) Financial Reporting Lab has issued a valuable infographic, highlighting the information investors are looking for from companies at this challenging time.

It is important that companies do not sacrifice a long-term focus on value creation and preservation for short-term reporting – a balance needs to be struck to ensure effective communication to investors and other stakeholders such as employees, customers and suppliers. 

The majority of December and January year ends have now reported; many of these reporters addressed COVID-19 in areas such as risks, outlook statements and financial statements.

For March year ends and upwards reporting will need to be more expansive, covering both the traditional areas of reporting and the new disclosures in relation to purpose, culture and section 172. 

Below we have detailed our checklist for reporting on COVID-19 in the annual report. 

Traditional disclosures                                                        


  • The Chair’s statement should offer a broad company statement about COVID 19 and updated outlook.
  • The CEO’s review should give a more substantial explanation of the operational and financial effects.
  • The financial review should address the impact on performance and going concern.

Business model and value creation 

  • Companies should consider if changes are needed to the business model in light of disruptions and resilience.

Principal risks and uncertainties

  • Risks – introduce COVID-19 as a principal and emerging risk where material and consider proving a deep-dive pull-out on it.
  • Viability statement – add details of how COVID-19 has been considered/modelled in the long-term viability statement. If the timeframe of the statement hasn’t changed, explain why. 


  • Financial statements – financial reporting technical areas will be significantly impacted by COVID-19 in areas such as financial Instruments, Impairment assessment, government grants and income taxes to name but a few. It would be highly beneficial to consult your auditor in relation to these matters.

While addressing the traditional areas of reporting, it is important not to lose sight of the new disclosures. 

Purpose and culture 

  • Purpose – it’s important not to lose sight of purpose as your animating force. The report should address how you are fulling your purpose during this time of uncertainty. 
  • Values and culture – show how your actions are aligned to your values and behaviours.

Section 172 and long-term consideration 

  • Section 172 of the Companies Act 2006 imposes a general duty on every director to act in a way they consider, in good faith, would be most likely to promote the success of the company for the benefit of its members as a whole. Given the current situation we would expect section 172 to be a focal point of the annual report.

At Luminous we would recommend that reporters focus on engagement and how the Board has balanced the survival of the company against the needs of stakeholders and the other section 172 factors.

For update information on COVID-19, visit our hub at

If you would like to discuss any of these points with us here at Luminous, please get in touch.