On 10 June 2018, the Department for Business, Energy & Industrial Strategy published draft regulations - the Companies (Miscellaneous Reporting) Regulations 2018 – which require, amongst other things: (i) require companies of a "significant" size to explain how their directors comply with the requirements of section 172 of the Companies Act 2006 to have regard to stakeholders; and (ii) to require quoted companies to report annually the ratio of CEO pay to the average pay of their UK workforce.

For regulated firms in the financial services sector it is important to note that for Company Directors, they will need to comply with both company law and regulatory duties under SM&CR. A key challenge when thinking about implementation may arise from the fact the two regimes do not always operate in a clearly integrated and consistent manner.