Private equity – updated Walker guidelines and 2024 annual report

The Private Equity Reporting Group (PERG) has published an updated version of the Walker Guidelines for Disclosure and Transparency in Private Equity, as well as its 2024 annual report on compliance with the Guidelines.

Updated Walker Guidelines

The Walker Guidelines aim to improve disclosure and transparency in the PE industry and apply to the largest portfolio companies (meeting certain size and employment thresholds) and the PE firms behind them. Portfolio companies are expected to make certain disclosures in their annual reports including around ownership, board composition and other matters concerning the business.

PERG and the British Private Equity & Venture Capital Association (BVCA) have conducted a full review of the Guidelines and have published a feedback statement alongside the updated Guidelines.

Key points to note are:

• the thresholds that determine whether a portfolio company falls within the scope of the Guidelines have been increased;
• annual assessments will be introduced, so that companies that grow significantly can be brought into the scope of the Guidelines and companies that reduce in size will be able to fall out of scope (though this requires further work so has not been introduced at this stage); and
• the disclosure requirements have been updated to make them more comparable to those that apply to FTSE 250 companies.

The new guidelines will first be reported on by PERG in December 2026 and will cover companies within scope from 1 January 2025 to 31 December 2025.

Annual report

PERG has published its seventeenth annual report on the private equity industry’s conformity with the Walker Guidelines. Points of interest include:

• portfolio companies did not achieve a similar level of good additional disclosure in their audited financial statements this year, with only 43% doing so to at least a good standard and the remaining 57% doing so to a basic standard. However there were a large number of annual reports that were very close to achieving ‘good’ overall, only missing out due to one area of disclosure;
• the quality of disclosure in respect of social, community and human rights issues remained unchanged compared to last year, although the quality and depth of the disclosures in relation to environmental matters improved again;
• all BVCA members in scope included information on their website about themselves, their investors and their portfolio companies; and
• the vast majority of portfolio companies published their annual reports and mid-year updates in a timely manner.