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Publication duties
Unquoted companies must publish the section 172(1) statement on a website they maintain and are named on. Access, and a hard copy, must be free. The statement stays up until the next year's statement appears. If none is due, it stays until the next financial year ends. This applies to financial years beginning on or after 1 January 2019.
A reference note from Dan Malone, who builds software products.
The rule
“The section 172(1) statement must be made available on a website that— (a) is maintained by or on behalf of the company, and (b) identifies the company in question.”
The facts
| Field | Value |
|---|---|
| Who must publish on a website | An unquoted company that must include a section 172(1) statement in its strategic report must publish it on a website. Source |
| Who is outside the statement duty | A company that qualifies as medium-sized for the financial year does not have to make a section 172(1) statement. Source |
| When the duty started | Regulations 2 to 9 and 11 to 19 apply to financial years that begin on or after 1 January 2019. Source |
| Which website counts | The website must be maintained by or on behalf of the company, and it must identify the company. Source |
| No fee, and no gate beyond what the law requires | Access to the statement, and a hard copy from the website, must not need a fee. No other restriction is allowed, except where an enactment or regulatory requirement makes it necessary. Source |
| How long it stays up | It stays available until the next year's statement goes up. If no statement is due, it stays until the end of the next financial year. Source |
| How fast it must go up | The statement must be made available on a website as soon as reasonably practicable. Source |
| Downtime that is disregarded | A gap is disregarded if the statement was up for part of the period. The failure must also be wholly outside what the company could reasonably prevent. Source |
| Who commits the offence | On default, an offence is committed by every officer of the company who is in default. Source |
| Maximum fine | The offence carries a fine up to level 3 on the standard scale. Level 3 is £1,000 for offences committed on or after 1 October 1992. Source |
| A second web page duty | An unquoted company with a statement of corporate governance arrangements must also publish it on a website. The same access and duration rules apply. Source |
| Governance statement threshold and content | The trigger is more than 2,000 employees, or turnover over £200 million plus a balance sheet total over £2 billion. The statement names the code applied, how it was applied, and any departures. Source |
The artefact
What goes wrong
/01
The statement lives only on a filing portal or a third-party host. The company neither maintains that site nor is named on it.
/02
The page sits behind an investor login, a registration form or a cookie wall, so access is restricted.
/03
The old statement is removed before the new one is published, which leaves a gap in the required period.
/04
A site redesign or CMS migration breaks the URL, and nobody notices until an auditor asks.
/05
The statement exists only inside a large scanned PDF, so it cannot be searched or read by a screen reader.
/06
The web page still shows a statement from two years ago, because no owner was named for the annual update.
/07
Only the listed-company style investor section is built, so an unquoted group has no home for the statement at all.
/08
The corporate governance statement is published but the section 172(1) statement is not, or the reverse.
Who supplies this
Membership body for company secretaries. Publishes guidance and templates on directors' duties and narrative reporting.
https://www.cgi.org.uk/
Sets out content expectations for the strategic report and the section 172(1) statement. Free to download.
https://www.frc.org.uk/library/standards-codes-policy/accounting-and-reporting/annual-corporate-reporting/guidance-on-the-strategic-report/
UK corporate reporting agency. Builds annual report and governance web pages for listed and private companies.
https://www.emperor.works/
UK reporting agency. Produces annual report microsites and governance sections alongside the printed report.
https://design-portfolio.co.uk/
Corporate reporting and communications agency. Writes and designs governance and stakeholder content.
https://www.ry.com/
Hosted corporate and investor websites with managed content updates and long-term URL stability.
https://www.investisdigital.com/
Send the duty, the deadline and where it has to sit. What comes back is a written scope for the page, or a straight answer that you do not need one.
Send the briefLast checked 2026-09-01 · Published 2026-09-01
This page is reference material, not legal advice. Your advisor owns what applies to you.