The ACT argues for the retention of much of the existing disclosure regime for listed companies, even if beyond the Directive requirements e.g. the need for prelims, and for shareholders over 3% to disclose their interests.
In implementing any European Directive there will always be a debate whether to incorporate into UK law the basic minimum specified in the Directive or whether to go beyond those core requirements. In our response to the recent Davidson review we agreed that it was a laudable aim to avoid over regulation, however there can often be times where UK regulation already goes further than a new Directive in which case one needs to take care that rules introduced for valid reasons are not automatically revoked.
In attempting to avoid “gold plating” there is a risk of “throwing out the family silver”. Many of our comments in the following will be in relation to maintaining the good regulatory features of our existing disclosure and transparency regimes.
