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Transition Newsletter – Edition 4

Published:  14 August 2026
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Written by:
Director
FRP Transition London
Director
FRP Transition London

Welcome to our latest edition of the FRP Transition Network Newsletter. This will be a slightly longer edition to account for the summertime break.

However, as we move into the second half of 2026, UK business continues to face a familiar challenge: making important decisions in an environment that remains uncertain, complex and fast-moving.

The headlines suggest a mixed picture. Inflation has eased significantly from its peak, growth has returned, and consumer confidence has shown signs of improvement. Yet businesses continue to wrestle with rising labour costs, energy price volatility, geopolitical uncertainty and cautious investment conditions. Independent forecasts continue to point towards modest UK growth of around 1% during 2026, with inflation expected to trend lower but remain above the Bank of England’s target for some time.

Looking ahead to the remainder of 2026, economists broadly expect a period of modest growth rather than rapid expansion.

The key themes include:

Growth Remains Positive – But Fragile
Most forecasts expect UK GDP growth to remain around 1%–1.5%, supported by consumer spending, public investment and continued strength in services sectors.

Inflation Still Matters
Although inflation has fallen significantly, many analysts believe the “last mile” back to target will be the hardest. Labour costs and energy prices remain important risks.

Investment Decisions Are Being Delayed
Recent business surveys suggest firms remain cautious about committing capital. Many are waiting for greater certainty around energy costs, interest rates and the wider geopolitical environment.

Productivity Is Back on the Board Agenda
The UK’s long-term productivity challenge continues to dominate economic debate. Increasingly, organisations are focusing on technology adoption, AI, automation and operating-model redesign as routes to sustainable growth.

In this issue

FRP News and Insights

• IIM 2026 Survey – a big thank you

From correction to conviction: Investment decisions in Retail
Philip Kay (Director – Real Estate Advisory)

Retail’s June bounce is welcome, but the real test is what retailers do next
Tony Wright (Partner – Restructuring Advisory)

Vehicle hire sector: still investable, but no longer a passive asset-backed play
Raj Mittal (Partner – Restructuring Advisory)

Five questions CFOs and Boards should ask before signing off non-financial disclosures
Alexis Ioannidis (ESG Director – ESG Services)

FRP’s Decision Economy Breakfast: Why Better Decisions Matter More Than Ever
Angie Boothroyd (Director, Governance – One Advisory London) Jim Davies (Partner –
Financial Advisory)

Growth at FRP Advisory:

A new service has been launched across Public Company Advisory, with Rick Thompson and Philip Davies joining as Partners working nationally.

We’ve opened new offices across the East of England, with our continued expansion across East Anglia.

Corporate Finance team have added new joiners including, Peter Aspinall as Partner in London, to help further strengthen our technology M&A team and Scott Ellis joins our Cardiff team as Director.

On the restructuring side, Emma Thompson has joined as a Partner in London strengthening our contentious insolvency and cross-border asset recovery capabilities.

Some summertime reading and listening

• Insights Worth a Read or listen
Curated articles and podcasts we think are genuinely useful.

• Guest article
UK Carbon Border Adjustment Mechanism (CBAM):
Carbon Data is Becoming a Commercial Asset

• Events of Interest
Upcoming sessions and discussions to keep you connected and ahead of the curve.

Thanks for all the feedback so far. Please do keep it coming, we want to make sure this is always a genuinely useful platform of CPD, peer learning and support for you.

Warm wishes,
Susan and Lincoln

News and Insights

Our latest news and work form across the business.


IIM Interim Management Survey 2026 

We wanted to say a BIG THANK YOU for our ranking in this years IIM survey. Whilst we never view what we do as traditional recruitment, we are very grateful for the comments and support resulting in us placing 30th (Gold rank) out of 60 providers. 

If you have not seen this years survey, there were some stand out stats including: 

1. Signs of Recovery, But the Market Remains Challenging

The interim market showed modest improvement in 2026, with more interims securing assignments, average billed days rising from 133 to 148, and fewer people reporting extended gaps between assignments. However, sentiment remains cautious, with 41% still predicting a market decline over the next 12 months.

2. Day Rates Hit a Milestone

Average private-sector day rates exceeded £1,000 per day for the first time, reaching £1,004. Overall average day rates edged up to £907, while the gender pay gap narrowed slightly, with female interim rates increasing faster than male rates.

3. Fractional Leadership Is Becoming Mainstream

For the first time, the survey explored fractional assignments and found that 25% of recent assignments were fractional, confirming that organisations are increasingly embracing flexible access to senior leadership expertise rather than traditional full-time interim appointments.

4. Interim Careers Continue to Mature

The profession is becoming more experienced. Average tenure as an interim increased to 10.8 years, nearly half of respondents have been interim managers for more than a decade, and the average interim age rose to 55.2 years.

5. Diversity Is Improving Slowly

Women now represent almost 28% of UK interims, the highest level recorded by the survey, while representation from ethnic minority backgrounds continues to increase gradually. Although interim management remains male-dominated, the long-term trend is moving in a positive direction.

From correction to conviction: Investment decisions in Retail

Philip Kay (Director – Real Estate Advisory)

Retail is investable again! …but only for those making clear and disciplined decisions on capital, assets and portfolios. Retail has been repriced and capital is paying attention.

Reset in values to investable entry points:

The fall in retail values has been consistent over the last decade or so, more so in the high-street retail and shopping centre sub-sectors. However, over the two to three years following Covid, investors have increasingly perceived retail values to have reached a bottom. Investors more recently have been transacting at double-digit yields, attracted by both healthy cash-on-cash returns but also a tangible expectation of yield compression in the medium term.

Is lender appetite returning?

Whereas lender appetite to fund retail parks remained strongly consistent throughout this extended period, certain lenders have, over the last couple of years, begun to exhibit appetite to fund both high-street retail and shopping centre assets, particularly where there is a strong food/convenience anchor tenant. This is particularly evident within the more conservative leverage lenders (e.g. high-street banks) where legacy retail non-performing loans have been purged from loan books.

Is retail moving back into “core” lending?

Due to the increased liquidity amongst investors as a result of the attractive entry levels, retail as a target sector for lenders has returned. It is also worth noting that this should be considered on a relative basis compared with other asset classes.

Liquidity from lenders is generally at an all-time high across all real estate sectors. However, certain sectors present challenges. For example, the office sector where, despite recent positivity, some lenders remain cautious and ‘beds and sheds’, where competition amongst lenders is fierce. This has opened the door to an increased appetite to lend on retail assets to meet lending targets in a sector viewed as back in vogue.

A different model: Income is now shared, not fixed

Along with the hospitality sector, turnover rents have now become an integral part of the retail sector and have created more alignment than was ever present historically, with downside protection and sharing of upside a clearer motive on both sides of the landlord and tenant dynamic. That said, turnover rent is not without risk, and fixed income retains obvious appeal, particularly for funded investments where certainty of cash flow remains an important consideration.

The introduction of turnover rents has rebalanced the historic landlord/tenant relationship to become much more collaborative as individual store trading is now a pre-requisite to establish an open and equitable assessment of turnover rents.

Is it a polarised market – where performance is driving capital?

Whereas retail parks have performed consistently well (and attracted consistent levels of lender liquidity), this particular sub-sector could now be considered overcrowded from an institutional investor perspective. The current perception of value lies more in the shopping centre sub-sector where a more active asset management approach is required in order to drive rental tone and values.

From a debt perspective, certain situations remain harder to finance. For example, single-tenant risk where a lease event, such as a break or expiry, could occur within the loan term and leave lenders with an income problem. This structural income profile is not unique to retail and can be seen across other real estate asset classes.

Within retail, lenders may still be cautious on high-street and shopping centre assets, particularly where long-term voids point to weak occupier demand in that specific location. A clear business plan becomes even more important in giving lenders confidence in their underwriting, including where alternative retail uses, such as food court operators, form part of the strategy.

Re-purposing is no longer optional – it’s the value strategy

The decline of larger single-store department stores within shopping centres (e.g. Debenhams, BHS, House of Fraser) has opened the door to a repositioning of these larger single spaces to be repurposed into smaller retail units or even converted into other asset classes (e.g. residential or hotel).

As retailers rely less on upper-floor storage, driven by more efficient logistics and distribution, many shopping centre landlords are having to rethink the role of this space. For some, that means testing the viability of alternative uses, including hotel, residential or other mixed-use schemes.

Only those investors and developers comfortable with active asset management will succeed in successfully managing these assets through a period of transition. A passive investment approach will only result in more obsolete space.

Retail’s June bounce is welcome, but the real test is what retailers do next

Tony Wright (Partner – Restructuring Advisory)

There has been some welcome good news for retailers. 

Consumer confidence has seen its strongest improvement in nearly three years, and retail sales came in ahead of expectations in June. 

After months of pressure on both businesses and households, that matters. But one stronger month is not the first sign of a sustained recovery.

If you look behind the numbers, promotions and warmer weather appear to have helped unlock spending, particularly across online and clothing retail. Higher sales are clearly positive, but if growth has been helped by discounting, seasonal demand or short-term weather effects, the margin benefit may be thinner than the headline numbers suggest. In other words, more activity does not always mean stronger performance.

That distinction is important as retailers need to know where demand is genuinely improving, where customers are responding to offers, and where margin has been traded for volume. Those answers will shape decisions on stock, pricing, staffing and investment over the coming months.

However, there is still room for cautious optimism. Consumers appear to be feeling more positive than they have for some time, even if the wider picture is still uncertain.

There may also be opportunities ahead. With the new PM, Andy Burnham, now setting out a more devolved, pro-business agenda, retail could have a bigger role to play in local growth, high street regeneration and investment across the regions. His early focus on cost-of-living support, regional decision-making and business rates reform will be watched closely by the sector. For retailers, the opportunity is to be ready to respond to any policy changes that could ease pressure, where investment may become more attractive, and how quickly they can react if conditions improve. 

The recent re-escalation of the US-Iran conflict has again added pressure to global energy markets, which could feed into inflation, logistics costs and consumer spending. So yes, June’s stronger sales are encouraging, but they should be seen as early signs of improvement, not proof that those improvements are here to stay.

Vehicle hire sector: still investable, but no longer a passive asset-backed play

Raj Mittal (Partner – Restructuring Advisory)

For years, vehicle hire was often seen as a relatively defensive corner of the asset-backed market: tangible assets, visible security, established funding structures and a broad customer base spanning business-critical sectors. That investment case has not disappeared, but it has changed materially.

Today, the vehicle hire sector is less predictable, more operationally exposed and significantly more sensitive to management quality, contract strategy, end-market conditions and fluctuating asset valuations than many lenders and investors have historically assumed. In other words, it is no longer enough to just take comfort from the fleet valuation at the point of purchase.

The sector can still offer attractive lending and investment opportunities, but it should now be approached with a different mindset: not as a straightforward secured asset play, but as an operating business whose asset values, cash generation and debt service capacity are increasingly interdependent.

Why the old lending thesis is under pressure

The traditional view of vehicle hire relied on a relatively simple model:

• assets could be acquired from manufacturers with attractive discounts;

• utilisation would generally remain resilient;

• depreciation and residual values were broadly predictable;

• debt was serviceable from stable income streams;

• maintenance costs were relatively low; and

• downside was mitigated by recoverable fleet value.

That model has become harder to rely on.

Over the past two to three years, the sector has been hit by a combination of pressures that have fundamentally altered its risk profile. Residual values have become more volatile. Acquisition economics have tightened. Borrowing costs have increased. Fraud has become more commonplace in the sector. Maintenance spend has risen sharply. And some of the most important customer segments, particularly logistics and transport-related operators, have faced weaker trading conditions of their own.

Individually, each of those factors is manageable. Together, they challenge the core assumption that vehicle hire is inherently low risk because it is “backed by metal”.

It may still be asset-rich, but it is no longer automatically cash-generative, margin-protected or easily recoverable in downside scenarios.

The key shift: from asset-backed lending to operational credit analysis

The most important change for lenders and investors is this:

Fleet value alone is no longer an adequate proxy for credit quality.

Continue reading the full article here:

Five questions CFOs and Boards should ask before signing off non-financial disclosures

Alexis Ioannidis (ESG Director – ESG Services)

As many UK companies prepare, finalise or review their annual reports, the quality of non-financial information is coming under greater scrutiny.

ESG reporting has moved on. It is no longer enough to include a sustainability section and make broad statements about climate, people, governance or social responsibility. Investors, lenders, customers, regulators, auditors and procurement teams are increasingly reading non-financial information as part of their wider assessment of the business.

The issue I often see is not that companies are ignoring ESG. Most are not. The issue is that the information included in reports is sometimes too generic, too disconnected from the business, or not supported by the right evidence. Below are five common mistakes that can weaken the credibility of ESG and non-financial information disclosures.

1. Generic statements that could apply to any company

Many reports still include statements such as “we are committed to sustainability”, “we care about our people” or “we take climate change seriously”. These statements may be true, but they often tell the reader very little.

A good ESG disclosure should explain what the issue means for that specific company. For example, how does climate change affect its operations, costs, customers, suppliers or long-term resilience? How do people-related matters affect retention, service quality or delivery? How does the supply chain create risk? If the wording could be copied into another company’s annual report without much change, it is probably too generic.

2. No clear connection with the financial statements

Companies often discuss climate risk, energy costs, regulation, supply-chain pressure or emissions commitments in the ESG section, but there is no clear link with the financial statements, principal risks, business model or strategy.

That creates a gap. If an issue is described as important, the reader should understand how management has considered it. Does it affect costs, future investment, asset values, insurance, financing, procurement, regulatory exposure, margins or long-term resilience?

Not every ESG issue will have a direct accounting impact. However, where ESG risks or commitments are material, the report should show some connection between the narrative and the financial reality of the business. Otherwise, ESG reporting becomes a separate story sitting next to the financial statements, rather than part of the overall business report.

3. Overcommitting without reliable data or a credible plan

Another common mistake is making ambitious commitments before the company has the data, systems or governance to support them. This is especially relevant for emissions reductions, net zero targets, supplier commitments and climate-related statements.

A target is only useful if the baseline is clear. The company should be able to explain what is included, what is excluded, what methodology was used, whether estimates were applied, and how progress will be measured.

The risk is that companies make commitments based on weak emissions data or incomplete baselines. Later, when the data improves, the target becomes difficult to defend or needs to be restated. That does not look good.

It is better to be transparent about data limitations and show a clear improvement plan than to make commitments that are not yet properly supported.

4. Scenario analysis that has no real connection to the business

Climate scenario analysis is another area where reports can look sophisticated but say very little. Some companies describe different climate scenarios, but the analysis is not linked to their actual business activities.

The question is not whether a company has used a 1.5°C, 2°C or higher warming scenario. The question is what that scenario means for the business. Could carbon pricing affect costs? Could extreme weather disrupt operations? Could regulation change customer demand? Could insurance become more expensive? Could assets become less resilient? Could suppliers be affected?

If scenario analysis does not connect to the company’s assets, supply chain, customers, regulation, costs or financial planning, it becomes a theoretical exercise. For scenario analysis to be useful, it should help the board and management understand risk and make better decisions.

5. No continuity with previous years’ disclosures

ESG reporting should not restart every year. Readers need to understand what changed from the previous year. Were emissions reduced, or did the reporting boundary change? Was a target achieved, or quietly removed? Were previous risks followed up? Were KPIs changed? Was the baseline restated? Were prior commitments updated?

This is often missing. A report may look fine when read in isolation, but if you compare it with previous years, you sometimes see gaps. Targets disappear. Metrics change. Commitments are not followed up. Risks are rewritten without explanation.

That weakens credibility. Good reporting should create a clear thread between previous disclosures, current performance and future commitments. If something changed, explain why.

The governance test

Behind many of these issues lies a more fundamental question: who owns the information? If ESG information is included within the annual report, it should be subject to clearly defined ownership, formal review processes, and appropriate challenge mechanisms. The board or senior management should understand what is being reported, what assumptions are being used, and whether the information is consistent with the wider business strategy.

It is not enough to say that the board oversees ESG. The report should show how ESG matters are reviewed and whether they influence decisions.

Why this matters

Poor ESG reporting is not just a communication issue. It can affect investor confidence, lender discussions, procurement scoring, regulatory scrutiny and stakeholder trust. It can also expose weaknesses in data, governance, internal controls and risk management.

A credible ESG report should answer five basic questions:

1) Is the information specific to the business?

2) Is it connected to the financial statements and strategy?

3) Is it supported by evidence?

4) Is there clear governance and ownership?

5) Can progress be tracked year-on-year?

If you would like an independent review of your ESG report, climate disclosures or non-financial information, our team can help identify gaps, improve disclosure quality and strengthen alignment with established reporting expectations.

FRP’s Decision Economy Breakfast: Why Better Decisions Matter More Than Ever

Angie Boothroyd (Director, Governance – One Advisory London) Jim Davies (Partner – Financial Advisory) 

Business leaders are making decisions in an environment defined by uncertainty. Economic pressures, rapid technological change, evolving customer expectations and competing stakeholder demands mean there is rarely a perfect answer – only the need to act.

That was the focus of FRP’s recent Decision Economy breakfast event in London, where business leaders, investors and advisers came together at the 12th Knot Sea Containers, to explore one of the findings from FRP’s latest research: could faster decision-making unlock £13.7 billion of additional value across the UK mid-market each year?

Held under Chatham House Rule, the discussion was shaped by a panel bringing together different perspectives on decision-making: FRP’s Angie Boothroyd and Jim Davies were joined by Laura Phelps-Naqvi, Partner at Kiddy & Partners and Chartered Occupational Psychologist, who focused on leadership behaviour and organisational capability; and Alun Tribe CEO at IMIG who brought expertise in entrepreneurial, owner-manager decision-making and growth choices. Together, they examined what sits behind decision delays and how organisations can build the confidence to act more effectively.

Decision drag is rarely just a leadership problem

One theme emerged early in the discussion: delayed decisions are often a symptom of deeper organisational issues.

While leadership is critical, businesses that struggle to make timely decisions frequently face challenges around structure, accountability, culture and clarity of purpose. As organisations grow, the decision-making models that worked during the startup phase can become increasingly ineffective. Informal conversations and founder-led judgement often need to evolve into clearer governance frameworks, delegated authority structures and defined responsibilities.

The conversation echoed a broader finding from FRP’s Decision Economy research: decision quality and decision speed are closely linked to organisational clarity. Businesses that understand their priorities and empower people to act are often better positioned to seize opportunities when they arise.

Growth can create complexity

The panel explored how growth can contribute to the challenge of recognising opportunities quickly but taking longer to act on them. As organisations scale, decision-making naturally involves more stakeholders, more data and more operational complexity. Teams that were once able to act quickly can find themselves navigating additional reporting lines, governance requirements and competing priorities.

Rather than viewing this as an unavoidable consequence of growth, attendees discussed the importance of establishing clear ownership and accountability. Defining who is empowered to make which decisions can significantly reduce friction and help organisations maintain momentum as they expand.

Healthy challenge drives better outcomes

Another recurring theme was the role of debate in effective decision-making.

High-performing leadership teams are not necessarily those that agree on everything. Instead, they create environments where differing views can be aired constructively before a decision is reached.

The discussion highlighted the importance of psychological safety – ensuring people feel comfortable challenging assumptions, raising concerns and offering alternative perspectives. Without this, businesses can fall into the trap of “false harmony”, where apparent agreement masks unresolved issues that later undermine execution.

For leaders, the challenge is balancing robust debate with a commitment to collective action. 

Once a decision has been made, teams need alignment behind the outcome, even when individual views may differ.

Making decisions when uncertainty is the norm

FRP’s research shows that many mid-market leaders believe decision-making has become harder in recent years. That perception was reflected throughout the breakfast discussion. Economic volatility, changing policy environments, geopolitical uncertainty and shifting market conditions have created a backdrop where forecasting has become increasingly difficult.

Yet there was broad agreement that waiting for perfect certainty is rarely an option.

The panel explored how successful organisations are learning to operate with uncertainty rather than trying to eliminate it. This means maintaining a clear long-term vision while remaining agile enough to adjust course when circumstances change. It also means separating short-term noise from longer-term trends and focusing leadership attention on the factors that are most material to future performance.

Preparation matters

One of the most practical discussions centred on anticipation.

Leaders were encouraged to think about how organisations prepare for potential disruption before it happens. Whether considering cyber incidents, supply chain disruption or market shocks, businesses that have thought through possible scenarios are often able to respond more quickly and with greater confidence when events unfold.

Business continuity planning, crisis simulations and scenario exercises were all highlighted as ways organisations can strengthen decision-making capability before they are tested in real-world situations.

This reflects a wider theme in the Decision Economy research: the businesses creating value are often not those with access to perfect information, but those with the ability to act decisively when information is incomplete.

AI can support decisions – but only when the foundations are right

No discussion about decision-making would be complete without addressing artificial intelligence.

While panellists acknowledged the potential for AI to accelerate analysis, improve planning and support more informed decisions, they also warned against viewing technology as a silver bullet.

The consensus was clear: AI is only as effective as the data, systems and processes that sit beneath it. Organisations that layer AI onto fragmented information, inconsistent reporting or poor-quality data risk accelerating poor decisions rather than improving outcomes.

For many businesses, the biggest opportunity lies not simply in adopting AI, but in strengthening the foundations that allow technology to deliver meaningful insight.

Three priorities for leaders

As the session drew to a close, the discussion ended with on three practical themes for leaders looking to improve decision-making:

– Focus on what matters most by prioritising the issues that have the greatest impact on 

performance

– Create clarity through a clear vision, defined priorities and well-understood decision rights

– Empower the right people to act, while encouraging healthy challenge and open debate

The decision itself may never be perfect. But increasingly, the cost of waiting can be greater than the cost of acting.

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Worthwhile reading…

Interesting articles and thought-provoking insights


Podcast / Video

3 part mini series on becoming AI-Native

Possible Podcast

Article

Should You Appoint an Interim CEO?

Nicolas T. Deuschel, Robert Langan and Christoph Mât • HBR

Article

Andy Burnham’s first 100 days: five things contractors need from the new PM

Contractor UK

Article

The CFO’s guide to building a personal brand

Adam Zaki • CFO.com

Guest Article


UK Carbon Border Adjustment Mechanism (CBAM): Carbon Data is Becoming a Commercial Asset

Guest article by Alexis Ioannidis ESG Director, Financial Advisory

The UK’s Carbon Border Adjustment Mechanism (CBAM) is scheduled for 1 January 2027 and businesses should already be assessing how the legislation could affect their procurement strategies, supply chains and carbon reporting processes. Carbon data is moving beyond sustainability reporting and becoming an increasingly important component of commercial decision-making.

The purpose of CBAM is therefore straightforward: imported products should face a carbon cost broadly equivalent to similar products manufactured in the UK.

Importantly, CBAM is not intended as a trade barrier. Rather, it seeks to ensure that carbon pricing is applied more consistently, regardless of where goods are produced.

What is changing?

From 1 January 2027, UK importers of certain carbon-intensive goods will become liable for a carbon adjustment linked to the embedded greenhouse gas emissions within those products.

The initial scope includes:

Iron and steel

Aluminium

Cement

Fertiliser

Hydrogen

The mechanism applies to UK importers rather than overseas manufacturers. Businesses importing more than the applicable threshold of in-scope goods will be required to account for the associated carbon liability.

The amount payable will broadly depend on:

the embedded emissions of the imported product;

the prevailing UK ETS carbon price; and

any recognised explicit carbon price already paid in the country of origin.

While the methodology is technically complex, the principle is simple: comparable products should face comparable carbon costs.

The real challenge is unlikely to be the tax

In my view, the greatest challenge for many organisations will not be calculating the CBAM liability—it will be obtaining reliable emissions data. Most businesses already understand how to calculate costs once reliable information is available. What is often underestimated is the difficulty of obtaining consistent, auditable emissions data across international supply chains.

Many suppliers—particularly outside Europe—have limited experience in product-level greenhouse gas accounting. Others may calculate emissions using different methodologies, inconsistent boundaries or varying assumptions. This creates a governance challenge as much as an environmental one. Businesses will increasingly need to understand:

how supplier emissions have been calculated;

which standards have been applied;

whether assumptions are reasonable;

whether the information can withstand regulatory scrutiny.

In many cases, supplier engagement will become more important than the calculation itself.

Organisations with better visibility over supplier emissions will be better positioned to understand future carbon costs, manage regulatory risk and respond to increasing customer expectations.

For procurement teams, carbon data is becoming another commercial metric rather than simply an ESG disclosure exercise. Beyond compliance. One aspect that is sometimes overlooked is how closely CBAM aligns with wider ESG developments.

Many organisations are already investing significant effort in:

Scope 3 emissions measurement;

supplier engagement programmes;

Net Zero strategies;

Carbon Reduction Plans;

investor ESG reporting;

sustainability due diligence.

CBAM reinforces these activities rather than creating an entirely new agenda. For organisations that have already begun improving supply chain transparency, CBAM may represent a natural extension of existing governance processes rather than a completely new compliance exercise.

Preparing for implementation

Although the legislation comes into force in 2027, businesses should already be considering whether they have the information needed to comply.

Practical preparation should include:

identifying imported products that fall within scope;

reviewing commodity classifications;

mapping supplier locations;

assessing the availability and quality of emissions data;

engaging suppliers regarding calculation methodologies;

understanding potential financial exposure under different UK ETS price scenarios;

establishing appropriate governance and record-keeping processes.

Organisations that begin these conversations now are likely to experience a smoother transition than those waiting until implementation approaches.

Looking ahead

The UK CBAM is unlikely to be the last policy linking carbon performance directly to commercial competitiveness. Whether through carbon pricing, public procurement requirements, investor expectations or supply chain due diligence, businesses are increasingly expected to understand not only their own emissions but also those embedded throughout their value chains.

From my perspective, that is the broader message behind CBAM. It is not simply another environmental regulation. It reflects the continuing integration of sustainability into finance, procurement and corporate strategy.

Businesses that invest early in high-quality carbon data, stronger supplier engagement and robust governance are unlikely to benefit only from regulatory compliance. They will also be better positioned to make informed commercial decisions in a market where carbon is becoming an increasingly important component of business performance.

Interesting events

Some upcoming events we think you might find valuable.


IFT National Conference 2026

18th September 2026

TMA UK Annual Conference 2026

12th November 2026

A few final words

A few final words

Thank you again for being part of the Transition network at FRP. 

As we’ve mentioned, this newsletter is designed for you. So please keep the feedback coming. 

Tell us what you want more (or less) of in future issues — insights, CPD, sector updates, events or anything else that would help you in your professional work.

Finally in order to stay connected, you need to keep your profile and permissions up to date on the Network.

For any problems updating your profile email lincoln.coutts@frpadvisory.com


Best wishes,
Susan and Lincoln

 

Do you have an idea for something else you would like us to include in future editions, please get in touch ​lincoln.coutts@frpadvisory.com​

Straightforward advice based on robust analysis from experts you can trust