Two EU Directives were passed in 2013 which require annual reports on payments to governments by companies in the extractive industries (mining, oil and gas and logging).

The UK government has now published a consultation paper on the early adoption of the EU requirements under one of the two Directives: the Accounting Directive.

The UK implementation will apply not only to large UK incorporated companies (large is defined by meeting 2 of 3 minimum criteria) and all UK incorporated listed companies, but also UK companies which are subsidiaries of overseas registered companies.

Once (and if) rules are implemented under the Dodd-Frank Act in the USA, for example, the European Commission has the capacity to designate it as an equivalent regime (which could exempt companies from the reporting requirement), although it is not clear in any event whether this recognition would be reciprocated.

Here is a link to our briefing summarising the main features of the proposals for UK implementation.

Responses to the UK consultation are due in a short timeframe – by 16 May 2014.

For further information, please contact Jennifer Bell, Partner, London, or your usual Herbert Smith Freehills contact