Provision 29: Stop Ticking Boxes and Start Delivering Proof

The game has changed for UK boards. Moving from trust to evidence-based governance.

John Hotham30 May 20261 min readCompany Secretarial

CoSec Board Room
CoSec Board Room

The 2026 UK Corporate Governance Code has changed the game. Provision 29 isn't a suggestion; it is a declaration of effectiveness. If your board is still relying on 'trust' rather than 'test', you are one audit away from a crisis.

Boards now need proof that material controls—operational and compliance—are actually working.

What are Material Controls?

Definition: Material Controls are the essential processes and systems—spanning finance, operations, and compliance—that ensure an organisation meets its strategic objectives and regulatory obligations.

Compliance Shield
Compliance Shield

The role of the Company Secretary has evolved from minute-taker to governance architect. You need to supply the evidence, not just the agenda.

Action List for CoSecs:

  • Build an assurance map. Link every major risk to a specific, tested control.
  • Test control simulations. Do not wait for a breach to see if your policies hold up.
  • Automate board packs. Spend less time formatting and more time analysing the data.

Proof Checklist
Proof Checklist

Our £149 Founding Member tier gives you the governance engine to satisfy the FRC without the overhead.

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