Commercially Connected shorts - 9 September 2026

This week we look at:

• Corporate reporting: does simplification lie ahead?
• Trade: EU Customs reform approved - major changes for e-commerce and importers
• Data: EU Data Act – next provisions to come into force
• Industry focus: UK aerospace and defence & Commercial Payments Bill

Corporate reporting: does simplification lie ahead?

On 7 September 2026, the UK Government launched its long-awaited consultation on modernising corporate reporting. The consultation is described as a “once-in-a-generation” review and contains a broad package of proposals which, if implemented, would significantly reshape the UK corporate reporting framework, aiming to reduce administrative “burdens” on UK companies and support long-term economic growth.

The key proposals and the practical implications for companies include:

• Proposed changes to company size categories, reporting thresholds and exemptions
• A possible restructuring of the financial reporting framework
• Potential reform of the distributable profits and capital maintenance regime
• Proposed changes to the strategic report, sustainability reporting, corporate governance reporting and remuneration reporting
• The move towards digital-first shareholder communications and the potential facilitation of fully virtual AGMs.

If implemented, the proposals could reshape how UK businesses approach annual reporting, governance and compliance obligations. The consultation closes on 30 November 2026. Companies may wish to consider whether to respond, and should assess how the proposals could affect annual report preparation, governance processes, audit requirements and shareholder communications.

Read more: UK: Modernising corporate reporting: Key proposals and next steps.

With thanks to Sarah Turner

Trade: EU Customs reform approved - major changes for e-commerce and importers

On 3 September 2026 the Council of the EU approved a wide-ranging reform of the EU customs regime, aimed at modernising customs processes, strengthening enforcement and addressing the growth of cross-border e-commerce. The next step is for Parliament to review the final text (later this month) and if approved it will go forward to publication.

Non-EU online marketplaces selling into the EU will become responsible for customs compliance and duty payments, backed by new penalties for non-compliance. The reforms also establish a new EU Customs Authority and a central customs data hub, while trusted businesses will benefit from streamlined customs procedures. New rules will begin to apply from 2027, with phased implementation continuing into the 2030s.

Businesses selling goods into the EU, particularly through e-commerce platforms, should review their customs compliance arrangements and supply chains now, as liability, reporting obligations and enforcement risks are set to increase significantly.

EU Data Act – next provisions to come into force

From 12 September 2026, the "access by design" requirements of the EU Data Act come into force. This applies to newly placed connected products, including smart home devices, connected cars, appliances and industrial machines. These products must be designed to give users default access to the data they generate in a usable, machine-readable format.

For a reminder of the scope of the EU Data Act, what’s in force and what is to come see our Executive Compliance Guide: EU Data Act| Navigating EU Law.

UK aerospace and defence: Commercial Payments Bill: tougher rules on payment terms

The Commercial Payments Bill has landed and it demands attention. Completing its Committee stage in the House of Lords on 21 July 2026, this isn’t a minor regulatory update: it’s a fundamental overhaul of how payment works in UK commercial contracts. For the Aerospace and Defence sector, from government buyers and prime contractors to SMEs and specialist suppliers, the implications are significant and far-reaching.

Here’s what you need to know: once the Bill comes into force, every new contract, whether negotiated bespoke terms or standard T&Cs, will need to actively engage with its requirements. Payment terms exceeding 30 days (for public authorities) or 60 days (for private sector buyers) will be automatically void and replaced by statutory defaults. Statutory interest at 8% above base rate can no longer be contracted out. And critically, even where parties believe exemptions apply, for example, because both contracting entities are large undertakings, the contract must expressly state the specific exemption being relied upon. Silence won’t suffice: get it wrong, and the default caps apply regardless of size.

We explore what the Bill means for the UK Aerospace and Defence industry so you can be prepared for when it is ultimately implemented: UK: Faster Payments, Tougher Rules: How the Commercial Payments Bill Could Transform UK Aerospace and Defence Contracting

With thanks to Mike Turner, Helen Amison and Laura Heeley