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Provision 29 Ready: Turn 2026 Compliance Into Competitive Advantage

Provision 29: What's Really Changing?

Provision 29 creates three game-changing requirements that put boards directly in the hot seat:

1. Direct Board Accountability

The shift: Boards—not audit committees or management—now own the entire process

Why it matters: Internal controls just became a C-suite governance priority. Board members face personal scrutiny over control effectiveness.

2. Mandatory Annual Reviews

The shift: Annual effectiveness reviews are now required, documented, and auditable

Why it matters: No more tick-box exercises. Reviews must be rigorous enough to support public declarations.

3. Public Transparency

The shift: Annual reports must declare control effectiveness to all stakeholders

Why it matters: Boards can't hide behind vague language. They're publicly vouching for their control systems.

Provision 29: Crisis or Competitive Edge

GRC SmartStart, Your Provision 29 Solution

When premium-listed companies need to declare control effectiveness under Provision 29, they turn to proven technology that delivers confidence, not just compliance. GRC SmartStart provides the integrated platform that makes board-level declarations possible—with the evidence and processes to back them up.

A Curated Solution for Provision 29 Success

GRC SmartStart isn't a one-size-fits-all platform—it's a modular ecosystem where you choose the capabilities that fit your Provision 29 requirements. Our experts have identified the core modules that address the regulation's demands, but you control the configuration.

Start with the essentials. Scale as you grow. Adapt as regulations evolve.

The Provision 29 Core Module Set

Based on 25 years of GRC experience, we've curated four essential modules that directly address Provision 29's board-level requirements:

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Risk Management

Conduct risk assessments, manage registers, track key risk indicators, define treatment plans, assess scenarios, centralise risks, and generate reports.

Why it's essential: Provides critical evidence for the board's annual effectiveness review and public declaration.

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Compliance Management

Centralise controls, automate monitoring, manage compliance checklists, track policies, oversee actions, monitor indicators, and define contracts.

Why it's essential: Supports the board's need to demonstrate ongoing compliance and material control effectiveness.

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Audit Management

Conduct & manage audits and audit plans, create and maintain audit checklists, identify and track findings, assign actions, and monitor resolutions.

Why it's essential: Provides critical evidence for the board's annual effectiveness review and public declaration.

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Business Continuity

Store and manage business continuity plans, conduct impact assessments, link to key services, test strategies, and track lessons learned.

Why it's essential: Ensures resilience is embedded throughout the broader control framework declared in annual reports.

Expand Your Foundation

Your Provision 29 compliance doesn't end with the core four. GRC SmartStart offers additional modules that many organizations add to strengthen their governance framework:

  • Incident Management - Capture incidents, conduct root cause analysis, track lessons learned

  • Planning - Set objectives, allocate resources, track performance, align with corporate strategy

  • Project Management - Define and track projects, stages, budgets, risks, and lessons learned

  • Actions - Define responsibility for objectives with automated notifications and tracking

25+ Years of industry experience.  
Optial solutions are implemented by Fortune 500 companies in 50+ countries.

Why Leading Organisations Choose GRC SmartStart 

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Any Organisation, Any Size

From a single user to a global workforce, Optial grows effortlessly with you.

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Scalability for Growth

Adjust workflows and processes without disruptions, ensuring long-term success.

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Global Usability

Engage teams worldwide with seamless adoption in local languages.

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International Flexibility

Manage multi-currency transactions effortlessly, maintaining compliance and financial clarity.

Complete Picture, Not Fragments

Unlike point solutions that create governance silos, GRC SmartStart connects your risk, audit, compliance, and business continuity functions into a unified control framework. When your board needs to declare effectiveness under Provision 29, you have one complete view—not scattered reports from different systems.

A Nordic bank integrated their JIRA incident system with Optial's platform, creating real-time bi-directional sync that eliminated manual re-entry and gave all stakeholders the same up-to-date record, regardless of where issues were first logged. Read More...

Evidence That Stands Up to Scrutiny

Provision 29 requires boards to publicly declare control effectiveness. SmartStart provides the audit trails, automated workflows, and documented evidence that give boards confidence to make these public statements. Every assessment, review, and remediation action is tracked and reportable.

The Reserve Bank of Malawi implemented our enterprise-wide GRC system across seven modules, creating transparency and accountability that strengthened their operational resilience and regulatory standing. Read More...

Built for Regulatory Change

With 25 years helping organizations navigate major regulatory shifts—from SOX to GDPR—we understand compliance isn't just about today's requirements. SmartStart's modular architecture and 100% backward-compatible configuration engine evolve with changing regulations, protecting your investment as new requirements emerge.

A Silicon Valley multinational has used our platform since 2012, seamlessly adapting through multiple regulatory changes by leveraging our flexible configuration capabilities. Read More...

Configurable Without the Complexity

When standard modules don't exactly match your needs, SmartStart's integrated Configuration feature delivers what your business wants:

  • Seamless Front-End Customisation - Meet exact business requirements through configuration, not coding

  • 100% Backward Compatibility - All configurations remain compatible across software updates

  • Rapid Results - Achieve implementation quickly, from proof of concept to full production

  • Evolves With Your Business - Adapt as business and regulatory drivers change

  • Low-Risk, Cost-Effective - Implement tailored solutions without development costs or risks

A commercial banking group transformed their annual risk assessment process across multiple countries, with bulk scenario retirement and custom cross-country reporting—all through configuration, not custom development. Read More...

Your Provision 29 Knowledge Hub

Stay Ahead of Provision 29​​

Don't let 2026 catch your board unprepared. Get the insights and tools you need to turn Provision 29 compliance into competitive advantage.

Get Your Complete Provsion Guide

Download your free Provision 29 guide. Get practical steps to meet the new UK governance requirements before they become mandatory.

What's inside:

  • Immediate practical guidance

  • Complete regulatory breakdown and timeline

  • The 3 board-level duties you must implement

  • How to turn compliance into competitive advantage

  • Implementation roadmap with key milestones

Don't let 2026 catch your board unprepared. Get the insights and tools you need to turn Provision 29 compliance into competitive advantage.

See SmartStart for Provision 29 in Action

Want to understand exactly how GRC SmartStart addresses your Provision 29 requirements? Book a personalised demo where we'll walk through your specific challenges and show you how our modular platform delivers the evidence and processes your board needs to confidently declare control effectiveness.

What to expect:

  • 30-minute tailored demonstration

  • Focus on your industry and organizational structure

  • Live walkthrough of Provision 29-specific workflows

  • Q&A with our GRC experts

  • No sales pressure—just practical insights

The clock is ticking. The choice is yours.

Join the organizations that are already turning regulatory requirements into operational excellence.​

Common Provision 29 Questions

Who must comply with Provision 29?

Companies with a premium listing on the London Stock Exchange—including commercial and investment fund categories. This applies to financial years starting on or after 1 January 2026.

What counts as a "material control"?

A control is material if its failure could affect stakeholder decisions. This includes financial, operational, reporting, and compliance controls. Think revenue recognition processes, cybersecurity frameworks, or regulatory reporting systems.

How does "comply or explain" work?

You must either meet Provision 29's requirements or clearly justify any deviations in your annual report. Weak explanations invite regulatory scrutiny and investor pushback—compliance is typically the safer path.

When should we start preparing?

Now. Effective preparation requires establishing board processes, implementing review frameworks, and gathering baseline evidence. Most organizations need 12-18 months to build the systems and processes needed for confident public declarations.

What's the difference between monitoring and reviewing?

Monitoring is ongoing oversight throughout the year. Reviewing is the formal annual assessment that leads to your public declaration. Both are required under Provision 29.

Can we delegate this to our audit committee?

No. Provision 29 explicitly requires the full board—not just audit committees or management—to take direct responsibility for the review and declaration.

What happens if we find control deficiencies?

You must describe any material controls that haven't operated effectively, plus the actions taken or proposed to improve them. Transparency about issues and remediation shows strong governance.

How detailed must our annual report disclosure be?

You need three elements: how the board monitored and reviewed effectiveness, a declaration of control effectiveness at the balance sheet date, and descriptions of any deficient controls plus remediation actions.

 

Still have questions about your specific situation?

Get Answers to Your Specific Questions

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