A new reporting requirement is being introduced meaning large companies and large limited liability partnerships (regardless of whether they are private, public or quoted) will need to publish details of their payment practices, policies and performance on a half-yearly basis.
This new requirement could affect large Academy Trusts later this month (March 2018).
Why has this reporting regime been introduced?
Businesses across the UK often experience severe administrative and financial burdens each year simply because they have not been paid on time.
Smaller businesses are often the worst affected and the Government is trying to improve matters for them.
The information collected will be made publicly available, and will help businesses assess the entities they intend to trade with.
Does this affect Academy Trusts?
Academy Trusts will be expected to meet the reporting requirements when they meet two or more of the following criteria on both of their last two balance sheet dates:
- £36m annual turnover (for academies this would be revenue income total)
- £18m balance sheet total (“gross assets” on your balance sheet)
- 250 employees (headcount)
For MAT’s, the limits apply at trust level, i.e. it is the totals for the trust as a whole that apply.
For those Trusts that have subsidiary trading companies, their figures must be included in the calculations and if applicable, their details will also need to be published.
Is there a deadline for submission?
For those affected, the information will need to be published within 30 days of the relevant reporting period.
If an Academy Trust meets the reporting limits above, it will be required to publish the relevant information covering the following periods:
- 1st September 2017 to 28th February 2018 (so 30th March 2018 would be the due date for the first submission);
- 1st March 2018 to 31st August 2018 (publish by 30th September 2018).
What information does an Academy Trust need to publish?
For each qualifying period an Academy Trust would be required to give details of their payment practices, policies and performance which would include details such as – standard payment terms; process for resolving payment disputes; average number of days to make a payment; whether suppliers are offered e-invoicing; etc.
The requirements are summarised at paragraph 41 on page 14 of the Government guidance (see “Detailed guidance” below).
How is the information published?
The information required must be published on the Government website established for this purpose, at https://publish-payment-practices.service.gov.uk/publish
You must first be registered with Companies House Single Service which can be accessed via the following link: https://beta.companieshouse.gov.uk/signin
Are there any implications for non-compliance?
Failure to make the necessary disclosure within the allocated deadlines is a criminal offence which could result in a fine to the Academy Trust.
The Department for Business, Energy and Industrial Strategy have issued guidance which gives examples to help you assess if you need to provide the information. This guidance can be found using the following link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/649941/payment-practices-performance-reporting-requirements-oct-2017.pdf