The Guidelines Monitoring Group (the “Group”) has spent the past few months consulting on its proposed amendments to Sir David Walker’s Guidelines for Disclosure and Transparency in Private Equity (the “Guidelines”) and here we present our feedback and final advice.

As we near the seventh anniversary of the launch of the Guidelines, the Group is publishing, alongside this feedback statement, a revision to Part V and Annex D of the Guidelines which sets out the enhanced reporting requirements for portfolio companies and private equity firms. As well as monitoring the industry’s compliance with the Guidelines, we have continuously reviewed how the Guidelines should evolve over time to ensure they remain relevant in the eyes of the industry’s stakeholders as they underpin the industry’s commitment to transparency. The amendments implement the Department of Business, Innovation and Skills’ new narrative reporting regulations that came into effect in October last year.

The Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2013 (the “Strategic Report Regulations”) necessitated amendments to the Guidelines as they removed the requirement for a business review in the directors’ report – which was the foundation for the enhanced disclosure requirements for portfolio companies – and moved this content, with a few additions, to a new report called the strategic report. The revisions to Part V and Annex D of the Guidelines are therefore focused solely on the requirements for portfolio companies and the enhanced disclosures required to be comparable to quoted companies.

As part of the feedback process we invited comments on the proposed revisions from interested parties including private equity firms, portfolio companies, advisers and any other stakeholders. We received three written responses from accountancy firms and bodies, and through the BVCA, met with 26 firms to ensure the changes proposed were fully understood. The meetings also provided those firms with an opportunity to voice their views, including areas were the BVCA and the Group could assist with compliance. In addition, we discussed the objectives and benefits of the Guidelines and section 3 of this statement explains why they remain important for the private equity industry.