UK Corporate Reform: Is Your Organisation on track for Provision 29?

The landscape of UK corporate governance is undergoing its most significant transformation in over two decades. With Provision 29 of the UK Corporate Governance Code taking effect in January 2026, directors face new responsibilities that mirror the stringent requirements of the US Sarbanes-Oxley Act.

This "UK SOX" provision demands that directors report on the effectiveness of their company's internal controls over financial reporting—a requirement that will fundamentally reshape how organisations manage risk and compliance.

For finance and accounting professionals, the question isn't whether these changes are coming, but whether your organisation is prepared to meet them head-on.

The UK Corporate Reform introduces three critical changes that directly impact financial operations:

1. Enhanced Director Accountability: Directors must now personally attest to the effectiveness of internal controls over financial reporting, creating individual liability for control failures.

2. Failure to Prevent Fraud Offence: Under the Economic Crime and Corporate Transparency Act 2023, companies must demonstrate "reasonable fraud prevention procedures" to avoid significant penalties.

3. Strengthened Regulatory Oversight: The new regulator, ARGA, will have enhanced powers to scrutinize compliance and impose sanctions for control deficiencies.

These changes represent more than regulatory updates—they signal a fundamental shift toward accountability-driven governance where manual processes and spreadsheet-based controls become liability risks rather than operational solutions.

Most UK organisations currently rely on manual processes for critical financial controls. Account reconciliations live in spreadsheets, journal entries lack standardized approval workflows, and control documentation exists across disparate systems.

This approach creates several compliance risks:

• Limited Visibility: Management cannot monitor or control performance in real-time

• Inconsistent Execution: Controls vary between departments and individuals

• Weak Audit Trails: Supporting documentation lacks centralized storage and version control

• Human Error Risk: Manual processes increase the likelihood of mistakes and omissions

When directors must personally certify control effectiveness under Provision 29, these manual systems become impossible to manage. The risk of material weaknesses—and the personal consequences for directors—demand a more systematic approach.

BlackLine transforms compliance challenges into competitive advantages through comprehensive automation of financial controls and processes. The platform addresses each aspect of the new requirements with precision and reliability.

1. Automated Control Framework Documentation

BlackLine Account Reconciliations creates standardized templates for every balance sheet account, enforcing company policy through defined procedures, documentation requirements, and approval workflows.

This systematic approach replaces inconsistent manual processes with a documented control framework that satisfies regulatory expectations.

Task Management functionality maps the entire financial close process as a comprehensive checklist, ensuring every control-related activity receives proper assignment, tracking, and documentation.

Directors gain confidence in their control environment through systematic execution rather than relying on individual accountability.

2. Enforced Control Execution and Segregation of Duties

The platform eliminates the possibility of bypassing critical controls. BlackLine Journal Entry enforces segregation of duties by preventing the same user from creating and approving journal entries.

Account reconciliations cannot achieve completion status without proper preparation and approval by designated individuals.

This systematic enforcement ensures consistent control performance across the organisation, addressing the primary concern of directors who must certify effectiveness under Provision 29.

3. Real-Time Control Monitoring and Exception Management

BlackLine provides real-time dashboards that offer immediate visibility into financial close status. Management can instantly identify outstanding reconciliations, overdue tasks, and control bottlenecks as they occur rather than discovering issues during monthly or quarterly reviews.

The transaction management functionality automatically flags unmatched transactions and unreconciled accounts, routing them for immediate investigation. This proactive approach shifts focus from reactive problem-solving to preventive risk management.

4. Comprehensive Audit Trail Creation

Every action within BlackLine generates an immutable audit log with user identification and timestamps.

Supporting documentation—invoices, bank statements, sub-ledgers—stores directly within relevant reconciliations or journal entries, creating a centralized evidence repository.

When external auditors arrive or the board requests compliance evidence, organisations have a single source of truth that dramatically simplifies the audit process and provides directors with verifiable proof to support their attestations.

Preparing for the 2026 deadline doesn't have to be complex. A successful strategy can be built on three foundational pillars:

1. Foundational Risk Assessment

Begin with a top-to-bottom review of your internal control environment. Identify your highest-risk processes, particularly those dependent on manual intervention and spreadsheets. This initial assessment creates the business case for targeted improvements and will ultimately serve as the foundation for your compliance roadmap.

2. Strategic Automation and Centralization:

Address the identified gaps by transitioning from high-risk manual controls to a unified, automated platform. By centralizing processes like account reconciliations and journal entries with a solution like BlackLine, you establish a “single source of truth.” This ensures that mandatory controls, such as segregation of duties, are enforced automatically and consistently across the organisation.

3. Continuous Monitoring and Validation

With an automated framework in place, shift your focus to ongoing oversight. Leverage real-time dashboards and exception reporting to monitor control effectiveness continuously, not just at quarter-end. This allows you to validate your control environment on an ongoing basis, giving your board the irrefutable evidence required to confidently mee their provision 29 attestation duties.

Organisations that proactively address UK Corporate Reform requirements stand to gain competitive advantages beyond compliance.

BlackLine's automation capabilities reduce operational costs, improve data accuracy, and free finance teams to focus on strategic analysis rather than manual control execution.

The platform's comprehensive reporting and analytics provide insights that drive better business decisions while maintaining the robust control environment directors need to confidently certify under Provision 29.

The January 2026 deadline for Provision 29 compliance approaches rapidly. Organisations that begin preparation now will navigate these requirements smoothly, while those who delay face rushed implementations and increased compliance risks.

BlackLine offers the proven platform and expertise to transform your control environment from a compliance burden into a strategic asset. Contact our UK team today to see how BlackLine's platform delivers the automated controls and centralized evidence your board needs to confidently attest to Provision 29.

Your directors' reputations—and your organisation's conformity future—depend on the decisions you make today.