For the first time, the board itself must declare whether its material controls were effective at the balance sheet date, not simply describe the framework around them.
And those controls aren't limited to financial reporting. They include financial, operational, reporting and compliance controls.
Bruce Cartwright, Chief Executive at ICAS, welcomed the shift, saying it "better balances governance needs and proportionate regulation."
Pav Gill, CEO of Confide and the Wirecard whistleblower, puts the stakes rather differently: "The strongest defence against emerging risks lies in sound, well-structured governance systems."
Both are right, in different ways. One captures why the FRC designed Provision 29 as it did. The other captures why getting it right matters.
Grant Thornton's 2025 Corporate Governance Review found that 45% of companies had only partially met the spirit of Provision 29.
The harder part, though, isn't technical at all. It's being prepared to put in an annual report that a material control didn't operate effectively, and explain what the board is doing about it.
That changes the conversation.
Provision 29 applies to companies in the FCA's commercial companies listing category and closed-ended investment funds. If your company is in scope and hasn't started preparing it needs to act now
On Wednesday, the MyDirector-OS Journal goes deeper: the judgement call the FRC deliberately left to boards, what audit committee chairs think about it, and the disagreement over how much guidance, and assurance, is enough.