IAS 24 Related Party Register Template

Related Party Register: [Entity or group] [Financial year]

Register and procedure to identify related parties, capture and approve related party transactions, track year-end balances and guarantees, draft the financial statement disclosure and support the external auditor. It is built for preparers applying IAS 24 Related Party Disclosures (IFRS) or FASB ASC Topic 850 Related Party Disclosures (US GAAP), with the auditor working under ISA 550 Related Parties, and it includes the US SEC disclosure review for SEC registrants (Form 20-F Item 7.B for foreign private issuers, Regulation S-K Item 404, 17 CFR 229.404, for domestic registrants) and the UK Listing Rules for London listed companies. IFRS, FASB and IAASB standards are cited by name and number only: obtain the standard or law for the normative text. Replace every [bracketed] value and every row marked Example. This is a document format, not accounting, audit, legal or tax advice.

Document control

Approvals

Revision history

Contents

1. 1. Purpose, scope and framework
2. 2. Identification criteria
3. 3. Roles and responsibilities
4. 4. Annual and event-driven declarations
5. 5. Register of related parties
6. 6. Transactions log
7. 7. Review and approval procedure
8. 8. Balances, commitments and guarantees
9. 9. Key management personnel compensation
10. 10. Intra-group transactions
11. 11. Disclosure drafting
12. 12. External audit support
13. 13. Controls and red flags
14. 14. Traceability matrix
15. 15. Glossary and references

1. Purpose, scope and framework

Related party relationships are a normal feature of business, but they create a risk that transactions are not on the terms that unrelated parties would agree, that they are not approved by people without a personal interest, or that they are hidden from shareholders and lenders. This register exists so that every relationship and every transaction is visible, approved by the right body and disclosed completely.

Use the register for three distinct obligations, which have different owners and different tests:

• Accounting disclosure. The financial statements disclose related party relationships, transactions, outstanding balances and key management personnel compensation. The framework sets the definition and the content of the note. Determine which framework applies to each set of statements (consolidated, separate, statutory).
• Corporate approval. Company law, listing rules and the entity's own articles decide who must approve a transaction with a related party before it is signed. These rules use their own definitions, which often differ from the accounting definition.
• Tax. Transfer pricing rules use another definition of associated or related enterprises and require arm's length pricing and documentation. Keep tax analysis in the transfer pricing files and link to them from here.

2. Identification criteria

Build the population from every route by which a party can be related to the reporting entity. Apply the authoritative definition in IAS 24 paragraph 9 (or the ASC 850 glossary for US GAAP) to each candidate and record the conclusion with a reason; do not rely on the categories below as a substitute for the standard. The categories are a collection checklist so that nobody is missed.

Record parties that you considered and concluded are not related, with the reason, in the same register with status "Assessed: not related". Auditors ask how management reached its population, and a documented negative conclusion is the strongest answer. Typical examples are a supplier whose owner sits on an advisory panel without decision rights, or an investor whose stake sits below the level at which the group evaluates significant influence.

Treat the date of the relationship carefully. A party is related only for the period during which the relationship existed. A director who resigned on 30 June is related for the first half of the year; their transactions after that date are disclosed only if the framework or law requires it. Record start and end dates in section 5 so that the transaction log can be filtered by period.

3. Roles and responsibilities

Separate the person who benefits from a transaction from every step of its approval and recording. A director who declares an interest leaves the meeting for the agenda item and does not sign the purchase order or approve the invoice. Write this rule into the delegation of authority so that system workflows enforce it, and test it in section 13.

4. Annual and event-driven declarations

Collect a signed declaration from each director, executive committee member and other KMP at least once a year, aligned to the year-end close, and within a set number of days after any change. The declaration asks the person to list close family members, the entities in which they or those family members hold control, joint control, significant influence or a management role, and any transaction or arrangement with the group in the year. Ask the person to confirm that the list in the previous declaration is complete and current, and show it to them pre-filled so that a "no change" answer is an informed one.

Explain why the information is needed and how it is protected. The form collects personal data about family members who are not employees, so limit access, record the lawful basis, and set a retention period. Store the signed forms with the company secretary, and keep only the derived party list in this register.

Event-driven declarations matter as much as the annual cycle. Require a new declaration within [30] days of an appointment, and ask KMP to update the company secretary before entering into any transaction with the group, not after. For a new director, collect the declaration before the first board meeting so that conflicts can be managed from day one.

5. Register of related parties

Keep the register sortable by entity so that each subsidiary can produce its own list for its statutory accounts. A party related at group level is often related to every subsidiary as well (for example a group director who is KMP of the parent), but some parties are related only to one entity. The separate financial statements of each entity need their own population, including fellow subsidiaries.

Link each party to its vendor and customer master records. The ERP flag is the main detective control: it lets the controller extract all postings with related parties at period end and compare them with the transactions log. Assign a single flag value per party ID so that the extract maps back to this register.

6. Transactions log

Check of the example: RPT-001 rent of EUR 35k for nine months from 2026-04-01 to 2026-12-31 is 9 x 35 = EUR 315k paid. Under IFRS 16 the group recognises a right-of-use asset and a lease liability, so the income statement shows depreciation and interest rather than rent; the disclosure describes the lease and shows the amounts the framework requires, so record both the cash paid and the accounting amounts in the supporting schedule. RPT-005 interest is 500 x 5.0% = EUR 25k for a full year.

Log arrangements that carry no price as well as those that do. A director who uses a company apartment, a parent that guarantees a subsidiary's bank facility without a fee, or a shareholder who provides an office free of charge are all transactions for disclosure purposes, even though nothing is invoiced. Record the nature and, where useful, an estimate of the value, and mark the amount column "nil consideration".

Avoid the phrase "on arm's length terms" in the log or in the disclosure unless the evidence supports it. Frameworks and auditors treat that statement as an assertion that needs substantiation. Where you only have partial evidence, describe the terms factually and let the reader judge.

7. Review and approval procedure

Every proposed related party transaction goes through the same steps before any commitment is made:

1. The business owner raises a request with the counterparty, the nature, the expected value over the contract life, the terms and the reason for choosing a related party over alternatives.
2. Legal and the company secretary identify which approval rules apply: the entity's articles, the delegation of authority, company law for the contracting entity, listing rules where shares are listed, and any lender consent required by facility agreements.
3. Finance checks the terms against comparable evidence (tenders, price lists, broker opinions, the transfer pricing benchmark) and records the conclusion in section 6.
4. The approving body decides without the interested person. Minutes record the declaration of interest, the person's absence from the vote and the reasons for approval.
5. The controller flags the vendor or customer in the ERP before the first invoice so that postings are captured from day one.

For SEC registrants, first decide which form applies. A foreign private issuer such as Corvid reports related party transactions in its annual report on Form 20-F under Item 7.B, and major shareholders under Item 7.A; Regulation S-K Item 404 does not apply to it. Item 7.B uses its own list of related parties, close to IAS 24 but not identical, and asks about the nature and extent of transactions and loans that are material to the company or to the related party, or unusual in nature; read the Form's instructions for the period covered and the content. Keep a separate 20-F column in the disclosure map so that no transaction falls between the two definitions.

For US domestic registrants, Regulation S-K Item 404(b) requires a description of the registrant's policies and procedures for review, approval or ratification of transactions reportable under Item 404(a), and identification of any reportable transaction where those policies were not required or not followed. The Item 404(a) threshold is transactions exceeding USD 120,000 since the beginning of the last fiscal year (or currently proposed) in which a related person has a direct or indirect material interest; for smaller reporting companies Item 404(d) uses the lesser of USD 120,000 or 1% of average total assets at year-end for the last two completed fiscal years. Check the current eCFR text and the instructions to the Item before relying on these points.

For companies with shares on an EU regulated market, Article 9c of Directive 2007/36/EC, as inserted by Directive (EU) 2017/828, requires Member States to define material related party transactions, to require their public announcement and approval by the general meeting or the administrative or supervisory body, and it allows certain exemptions. The thresholds and procedures are in national law, so apply the transposing law of the Member State of the company's registered office.

For a company with equity shares listed in London in the commercial companies category, the UK Listing Rules define related parties (including substantial shareholders holding 10% or more and directors, and their associates) and set a procedure for larger related party transactions: board approval with the conflicted director not voting, a sponsor's confirmation that the terms are fair and reasonable, and a market announcement. Since the 2024 listing reforms, shareholder approval is no longer the default for these transactions. Map each UKLR related party in section 5 and run the percentage ratio tests for each proposed transaction; check the current FCA Handbook text before relying on any threshold.

When a transaction happens without prior approval, do not hide it. Log it, mark the approval reference "ratification", put it to the approving body at the next meeting with an explanation of the failure, and record the control deficiency in section 13. Some laws do not allow approval after the event and make the contract voidable; take legal advice.

8. Balances, commitments and guarantees

Agree each balance to the ledger and, where practical, to a confirmation from the counterparty. Differences between the two sides often show a transaction that one side has not recorded. For the lease, attach the IFRS 16 schedule so that the liability, the right-of-use asset and the interest are traceable.

Assess loans and receivables from related parties for expected credit losses in the same way as other financial assets, and disclose any allowance and any expense for bad or doubtful debts as the framework requires. A related counterparty is not automatically low risk; an associate funded mainly by the group may be weaker than an external customer.

9. Key management personnel compensation

Define the KMP population for each reporting entity and date it. For the group, it is normally the board of the parent and the executive committee. For a subsidiary, it includes its own directors and managers with authority over planning and control of that entity, and can include group executives who direct it.

Collect compensation in the categories that IAS 24 paragraph 17 sets out (short-term employee benefits, post-employment benefits, other long-term benefits, termination benefits and share-based payment) and reconcile each category to its source.

Check: 2,140 + 160 + 20 + 0 + 380 = 2,700; 1,980 + 150 + 18 + 240 + 310 = 2,698. The FY2026 share-based payment amount of EUR 380k is part of the group's total share-based payment charge of EUR 500k; the remaining EUR 120k relates to other employees.

Company law and listing rules often require further individual disclosures of director remuneration in the management report or the remuneration report. Keep those workpapers separate and reconcile the totals to this table.

10. Intra-group transactions

Record intra-group flows by pair of entities and by type: sales of services, royalties, management fees, cost recharges, loans, interest, dividends, guarantees and cash pooling. The same matrix serves three purposes: the consolidation elimination, the related party note in each entity's statutory accounts, and the transfer pricing documentation.

Check: royalty 140,000 x 6% = 8,400 (CC-VN has no external revenue and pays no royalty; it is a cost-plus service provider). Interest of EUR 300k on EUR 6,000k at 5.0% for a full year is 6,000 x 0.05 = 300.

Agree both sides of every flow monthly. Unmatched intercompany balances at year-end delay consolidation and usually signal a cut-off error. For Vietnam, related-party and transfer pricing declarations follow Decree 255/2026/ND-CP; coordinate with the local tax adviser on the declaration form and deadline.

11. Disclosure drafting

Draft the related party note for each set of statements from sections 5 to 10. Work through the disclosure checklist for the framework and record where each requirement is met. The table below only maps topics to paragraph numbers and to this register; it does not state the requirements. Read the paragraphs themselves when drafting.

Example draft (FY2026, group statements): "The Group has no parent and no ultimate controlling party. Halden Holdings S.a r.l. holds 24% of the shares of Corvid Commerce Group plc and nominates two non-executive directors, and is a related party because it has significant influence; the Group paid it EUR 120k for a seconded treasury specialist. During the year, Corvid Commerce GmbH leased an overflow fulfilment hall in Halle from Hollin Properties GmbH, an entity controlled by a close family member of a director, under a ten-year lease starting on 1 April 2026; rent paid in 2026 was EUR 315k. The Group purchased software development services of EUR 180k from Linnet Digital Ltd, in which a non-executive director is a partner. Logistics services of EUR 1,260k were purchased from the associate Wrenfield Logistics, to which the Group has also lent EUR 500k at a fixed rate of 5.0%."

For an SEC registrant, the Form 20-F Item 7.B disclosure (foreign private issuer) or the Item 404 disclosure in the annual report or proxy statement (domestic registrant) is separate from the financial statement note and uses its own definitions and, for Item 404, its own threshold. Prepare a reconciliation between the two so that any transaction in one and not the other has a recorded reason.

12. External audit support

The external auditor performs related party procedures under ISA 550 (or PCAOB AS 2410 for US public company audits). In practice the audit team asks for the same evidence every year, so prepare one pack and hand it over with the year-end PBC list:

• the register of parties (section 5) with the identification approach and changes since last year;
• the transactions log, approvals and minutes (sections 6 and 7);
• the ERP extract of flagged postings and the reconciliation to the log;
• balances with confirmations (section 8);
• the KMP compensation reconciliation (section 9);
• the control testing results and deficiencies (section 13);
• the draft disclosure with the checklist (section 11).

The management representation letter contains representations on related parties that the auditor requests; agree their wording with the auditor rather than drafting from a model. Sign the letter only after the declarations are complete and the reconciliations are cleared, so that the signatories have a basis for what they confirm. See Management Representation Letter (finance/management-representation-letter).

Expect the auditor to search for undisclosed relationships, for example by reading board minutes, reviewing large or unusual transactions near period end, checking registry data on major suppliers and customers, and inquiring of people outside finance. Do the same review internally first and record the result.

13. Controls and red flags

Watch for indicators that a relationship has not been declared: payments to a supplier that nobody in procurement selected, prices well above or below market, unusual payment terms or guarantees, transactions approved by one person only, round-sum consulting fees, customers with the same address or bank account as an employee, and sales or purchases concentrated just before period end. Investigate each indicator, record the outcome, and add any newly identified party to section 5 with the date the relationship began.

14. Traceability matrix

15. Glossary and references

15.1 Glossary

15.2 References

Standard and licence note

Structure aligned with the related party requirements of IAS 24, FASB ASC Topic 850, ISA 550 and PCAOB AS 2410, which are cited by name and number only; no text from IFRS Foundation, FASB, IAASB or PCAOB publications is reproduced or paraphrased. Based on SEC Regulation S-K Item 404 (17 CFR 229.404) and the GAO Green Book (GAO-25-107721), US government works in the public domain, on SEC Form 20-F Item 7, and on EU, UK (including the FCA UK Listing Rules, cited by chapter only) and Vietnamese legislation cited by article or section. The register, procedure, controls and worked example are original text. Corvid Commerce Group, its entities, people and counterparties and every figure are fictional. Check the current official version of every cited standard and law, and the law of each jurisdiction where the group operates, before use. Template licence: MIT.