New and changed requirements

1.      

Task force on climate-related financial disclosures (TCFD)

2025/26 is the final year of the 3-year implementation of TCFD.

From 2025/26 entities should disclose how the organisation’s operations, strategy and financial planning are affected by actual and potential climate-related risks and opportunities.

Annex 7 to chapter 2

2.      

NHS Oversight Framework 2025/26

The NHS Oversight Framework has been updated in 2025/26. The disclosure requirements in annual reports have not changed but the example disclosure has been updated to reflect changes to the oversight framework.

Paragraph 2.111 and annex 3 to chapter 2: NHS Oversight Framework – example disclosure

3.      

Very senior manager (VSM) pay framework

The new very senior manager pay framework applies from 2025/26. The remuneration report must include a statement of compliance with the VSM pay framework and confirm approvals for pay cases where required. Any departures from the framework should be disclosed.

Paragraph 2.41

Minor changes and clarifications

4.      

Accounting officer signature

Further guidance on signatures of the accounting officer within the annual report and accounts has been added. There is no change to the requirements.

Paragraph 1.16

5.      

Fees and charges guidance

Updated guidance on how to measure the ‘full’ cost of a service for the purposes of fees and charges as provided in Managing Public Money (MPM) has been referenced in the relevant footnote of the FT ARM.

Paragraph 2.31

6.      

Fair pay guidance

HM Treasury has clarified that non-executive directors are outside the scope of the fair pay disclosures. This has been updated within the fair pay disclosure requirements.

Paragraph 2.92 and 2.94 and note accompanying the ‘Fair pay disclosures section’ for approach to prior year

7.      

Exit packages approval

Department of Health and Social Care (DHSC) now has delegated authority to approve non-contractual exit packages up to £300,000 that are not novel, contentious or repercussive. Previously all non-contractual exit packages required HM Treasury approval. The template disclosure has been updated.

There is no change to the requirement for NHS foundation trusts to seek approval (via england.vsmcases@nhs.net) before committing to any payment.

Annex 1 to chapter 2: exit packages

8.      

Certificate on summarisation schedules

Minor updates have been made to the example certificate on the summarisation schedules (often referred to as ‘TAC consistency statement’) to improve accuracy and clarity. There are no changes to the principles or requirements for consistency.

Separate reference to NHS England’s template provider accounting policies has been deleted because these are consistent with the Department of Health and Social Care (DHSC) group accounting manual (GAM).

Annex 2 to chapter 1: example certificate on summarisation schedules