Small company accounts filing changes: profit and loss filing delayed beyond 2028

Currently, most small and micro companies file ‘filleted accounts’, which contain the balance sheet and related notes only. The directors’ report, profit and loss (P&L) account and P&L notes all stay private.

The government previously said this would no longer be an option from April 2028.

At the suggestion of its Small Business Regulatory Taskforce (‘SBR Taskforce’), the government has paused this requirement while it undertakes a general review of Companies House and HMRC filing processes. You can read the update here.

In practical terms, this means small and micro businesses will still be able to file filleted accounts after 1 April 2028, keeping their turnover and profit confidential.

Is filing P&L information necessary?

The government wants to be able to check that companies are filing the right ‘size’ account and can cross-reference accounts to tax filings. However, P&Ls are already provided to HMRC which can be used for this.

The SBR Taskforce recommended a ‘Tell Government Once’ approach. This is where government services take a more joined-up approach to obtaining information. The government said they will explore viable options for this and produce a roadmap following next year’s Spending Review.

One option that might appear on this roadmap is that companies continue to file filleted accounts, but HMRC shares P&L information with Companies House to help challenge company size and the level of disclosure.

Does this mean nothing is changing for companies filing accounts?

Far from it. There are several changes coming to small company accounts.

1. More disclosures required in small company accounts

For periods starting on or after 1 January 2026, the new FRS 102 rules kick in, which require extra disclosures in Section 1A accounts.

Both full and filleted small company accounts will need to disclose

• Dividends paid or payable
• Share-based payments (including share options)
• Significant leasing arrangements (e.g. renting a building from a property company)
• Significant judgements around going concern
• Expanded revenue accounting policy
• Deferred tax assets and liabilities, including unused tax losses/credits
• Contingent assets, contingent liabilities, provisions and financial guarantee contracts
• Related party transactions and balances, even those at arms’ length, unless with wholly owned group companies.

Full small company accounts (but not filleted) will need to disclose

• Lease payments other than depreciation and interest
• Tax note, including breakdown of tax expense and reconciliation to accounting profit.

2. Mandatory software filing is coming for all companies

Accounts filed from April 2028 will need to be filed through commercial software. There is more information in the gov.uk article, including a list of software providers.

If PKF Francis Clark prepares your accounts, for example using Silverfin, you should not need to make any changes. PKF Francis Clark already file most accounts electronically, and our providers are preparing their iXBRL tagging services for the new requirements.

If you prepare and file your accounts yourself, you might need either new software, or assistance from an accountant to file these.

3. Additional Companies House filing requirements will be introduced

From April 2028 there will also be:

• A strengthened eligibility statement for all companies claiming an audit exemption
• A requirement that when documents need to be filed alongside your accounts, they are filed together (through commercial software) in a zip folder
• A limit to how many times a company can shorten its accounting period – mirroring the rules we already have for lengthening periods. This will mean companies can’t routinely shorten their period in search of a filing extension.

4. A wider review of Companies House and HMRC filing

The delay to P&L filing came from the government’s response to the Small Business Regulatory Taskforce. As part of this response, it promised to adopt a ‘Tell government once’ philosophy to filing and said it would “explore options to streamline Companies House and HMRC filing processes”.

There could be more changes coming once that review takes place.