Black Sun continues to be a strong supporter of changes to regulation that enhance the attractiveness and competitiveness of London’s markets.
One change in the new AIM Rules for Companies, effective 5 August 2026 (link below), giving AIM companies extra flexibility on governance disclosures by removing the requirement to report against a recognised governance code on a comply or explain basis.
Under the new rulebook, AIM companies ‘should consider a recognised corporate governance code for the purpose of guidance and informing its approach but is not required or expected to comply or explain against that code’ (Pt1, R.26).
Instead, they are asked to describe their governance approach across key topics such as: board composition; directors’ responsibilities, remuneration and performance; risk and controls; and shareholder engagement but won’t have to anchor every disclosure explicitly to the requirements of a specific, recognised, code.
In practice, this gives boards more freedom in how they tell their governance story, while still expecting them to be clear and accessible for investors. It moves the emphasis to how governance works in each company and away from mandating specific disclosures.
Currently, over 90% of AIM companies apply the Quoted Companies Alliance (QCA) Corporate Governance Code as their primary governance framework.
In a statement, the QCA recognised the change in the AIM Rules commenting that ‘the QCA Code has always promoted flexible, proportionate and principles-led governance that reflects the circumstances of individual growth companies’.
They said of the change, ‘we are confident that the QCA Code will remain the de facto investment-grade corporate governance framework for companies seeking to demonstrate quality, strengthen investor confidence and attract long-term institutional capital’.
The key question will be how boards use this freedom of choice in their governance disclosures. Will they continue to lean into the QCA Code’s flexibility, or start to experiment with alternative reporting approaches where that makes sense?
Equally important will be how investors and other stakeholders respond.
In our view, if the new rules result in clearer, more consistent explanations of governance, these changes have the potential to help strengthen confidence in AIM and, by extension, in London’s broader equity markets.
If you would like support with how to take advantage of the new AIM rules or to discuss how Black Sun can enhance your annual reporting, please contact:
Bob Crosbie-Dawson, Head of Business Development
bcrosbie-dawson@blacksun-global.com.
References:
AIM Rules for Companies - August 2026.pdf
QCA Statement - 5-Aug: A New Era for AIM: Delivering a Market Built for Growth
About Black Sun
Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 20 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world.
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