Accounting and Transparency Directives: key issues in transposition

The EU Accounting and Transparency Directives will require oil, gas, mining and logging companies to publish payments made to governments for access to natural resources. EU Member States have until 2015 to pass implementing legislation to bring payment reporting into law.

In the UK, the Department of Business, Innovations and Skills (“BIS”) has adopted regulations implementing the Accounting Directive (“AD”), while the Treasury and the Financial Conduct Authority will implement the Transparency Directive (“TD”) this month.

This note aims to share our experience of UK implementation and provide a checklist of issues that all implementing regulations must address. To protect the emerging global standard of payment reporting, implementation must be consistent across EU Member States, avoiding legislative errors which could be open to challenge in Court.