Everybody who bears the cost of a disclosure gets told the consultation is open. The people it describes are not on the list

A new reporting requirement arrives with an author. Somebody proposed it, somebody campaigned for it, a minister announces it and a trade body issues a response the same afternoon. It has a launch.

A removed requirement has a commencement date.

That asymmetry explains most of what happened in April 2025, when the statement British companies had to make about engaging with their employees stopped being required, and nobody outside the accountancy institutes appears to have written a word about it. There was nothing to attend. A schedule was amended and took effect the following April.

The consultation that opened on Monday will work the same way, and the mechanism is worth setting out because it is not a scandal and it is not going to be fixed by anyone noticing.

Ask who will respond to it. Finance directors, company secretaries, audit firms, the accountancy institutes, business federations, investor bodies, law firms writing client briefings. All of them competent, most of them thoughtful, and every single one of them a person or organisation that carries the cost of the reporting.

Now ask who will not respond. The people the disclosures describe.

That is not capture, and I want to be careful not to make it sound like conspiracy. It is the ordinary arithmetic of attention. A burden is felt by a specific person on a specific afternoon. The value of a disclosure is diffuse, delayed, and mostly accrues to somebody trying to answer a question years later. One of those constituencies has a reason to write in by 30 November. The other does not know the consultation exists, and would struggle to say what it stood to lose if it did.

Which produces a predictable direction of travel. Not because anybody is captured, but because the feedback the process receives is systematically from one side of the ledger. Ask a room full of people who fill in forms whether there are too many forms, and they will tell you the truth, and the truth will be yes.

Two honest qualifications, because this argument can be pushed too far.

A consultation is not a referendum. Departments are meant to weigh interests, not count submissions, and a good official knows which voices are missing from their own inbox. Trade unions and civil society organisations do respond to consultations, including this kind, and the TUC has a corporate governance position of long standing. Nobody should assume the room is empty.

And the burden is real. Ninety-eight thousand words in an average annual report is not a healthy document, and a hundred and fifty-two thousand for a FTSE 100 company is nobody's idea of transparency. Length is its own kind of concealment. The people arguing for less of it are not wrong.

The question is only which parts go. And the parts that go will tend to be the ones nobody in the room feels the loss of, which is a different test from the ones that matter least.

If you want to know what a system values, look at what it keeps when it is asked to shorten itself. Over eighteen months this one kept the payment terms it offers suppliers and let go of the account of how it treats the people who work there.

The consultation closes on 30 November. It is genuinely open, anybody may respond, and almost nobody who has ever been made redundant will.