Contents
Understanding the 2026 UK Corporate Governance Code Requirements
Strengthened internal control statements
The Code now expects boards to explain the scope of their material controls (financial, operational, reporting, and compliance), how they have been reviewed, and where any deficiencies exist. Finance leaders must be confident that their controls are designed well, operating consistently, and leaving a clear audit trail.
Annual declarations and board-level responsibility
The shift isn’t just technical, it’s cultural. Boards must sign annual declarations on control effectiveness, supported by clear documentation and management attestations. That requires reliable, centralised evidence rather than disparate spreadsheets or screenshots from banking portals.
The link with the ECCTA’s “Failure to Prevent Fraud” offence
The Economic Crime and Corporate Transparency Act introduces a strict liability offence for large organisations that don’t have adequate procedures to prevent fraud. Payment workflows and bank access are obvious hotspots. The right technology makes it far easier to demonstrate proportionate, effectively operating anti-fraud controls. (Still unsure what the UK corporate governance code is? In practice it’s the UK’s principles-based rulebook for listed companies, setting expectations for leadership, effectiveness, remuneration, relations with shareholders, and, increasingly, robust internal control. It sits at the heart of the UK code of corporate governance.)
Why Finance and Treasury Operations Are a Key Focus Area
The risk of manual processes and fragmented systems
Many enterprises still rely on staff to key payments into multiple online banking portals, download statements, and re-upload files into Enterprise Resource Planning Software (ERPs). Each manual touchpoint increases the chance of error, delays reconciliation, and makes it difficult to prove that controls work end-to-end.
Fraud and error vulnerabilities in payment workflows
Typical weak points include file tampering, credential sharing, and out-of-band approvals. Without consistent pre-submission validation and role-based access, it’s harder to deter insider threats and catch mistakes before funds leave the business.
The need for end-to-end visibility of cash and controls
Boards need timely, consolidated insight: where the cash sits, what has been approved, and what’s failed or been rejected, with a defensible record for auditors. That level of visibility is impractical when processes live in siloed bank portals.
Introducing Host-to-Host (H2H) Bank Connectivity
What H2H connections are and how they work
H2H establishes a secure, direct connection between your ERP/back-office systems and your banks. Payment files are validated, encrypted, and transmitted automatically; acknowledgements, status updates, and bank statements flow back the same way. No copy-and-paste. No portal hopping. Just straight-through processing. This kind of bank connectivity solution is fast becoming a critical part of the modern internal financial control framework.
Core benefits: automation, visibility, and security
With H2H, approvals are embedded in one place, exceptions are flagged in real time, and audit trails are generated as a by-product of the process. You achieve consistent controls across all banking relationships, domestic and international, while reducing cycle times and operational effort. Finance leaders increasingly rely on these bank connectivity solutions to support assurance and compliance.
Supporting internal controls and audit trails
Centralised dashboards show who approved what, when, and under which policy. Message receipts prove delivery; reconciliation feeds prove completeness and accuracy. The result is reliable evidence to support board attestations and external audit.
Strengthening Internal Controls Through H2H
Automated payment approvals and segregation of duties
Embed multi-eye approvals based on value, beneficiary type, or business unit. Ensure makers, checkers, and releasers are separated, and automatically enforce four-eyes (or six-eyes) for higher-risk transactions. Dynamic workflows keep you compliant without slowing the business.
Immutable audit logs and proof of delivery
Digitally signed files, time-stamped message receipts, and system-generated logs provide a tamper-evident record of activity. Auditors can trace a transaction from ERP initiation to bank confirmation in minutes.
Reducing insider fraud risk through access control
Remove the need for widespread portal credentials. Role-based access, MFA, and least-privilege permissions are applied centrally. Combined with pre-submission validation (e.g., beneficiary checks, format and scheme checks), this lowers the risk of error and deters internal misuse.
How Third-Party H2H Solutions Help Ensure Compliance
Faster implementation vs. in-house builds
Building one-off SFTP connections, file transformations, and UI tooling internally can take 6–18 months per bank. Third-party platforms like AccessPay bring pre-built bank integrations, proven transformation engines, and a ready-made control layer, compressing timelines to weeks, not years.
Continuous compliance updates and monitoring
Standards evolve (for example, ISO 20022), banks change specs, and keys expire. A dedicated provider monitors these shifts, updates mappings, rotates encryption keys, and maintains resilience, so your control environment stays current by default.
Reducing maintenance burdens and operational risk
24/7 monitoring, incident response, penetration testing, and evidence packs are part of the service. Your team focuses on policy and oversight; your provider keeps the pipes flowing and the proofs available. This is where finance automation compliance becomes easier to achieve in practice.
Preparing for the Future: ISO 20022 and Beyond
Adapting to new data enrichment and reporting requirements
High-value payment systems now require richer data: purpose codes, structured addresses, and (in some cases) Legal Entity Identifiers. H2H makes enrichment repeatable and consistently enforced, helping you avoid costly rejections.
Minimising failed payments and manual interventions
Pre-validation catches format errors and incomplete references before submission. Automated statement retrieval accelerates reconciliation and exception handling, keeping close processes on schedule.
Staying audit-ready as regulations evolve
Whether it’s emerging payment schemes or new governance expectations, an H2H layer gives you the flexibility to adapt without re-engineering your core finance systems. It reinforces the wider internal controls framework that auditors and regulators now expect to see.
Key Takeaways for Boards and CFOs
- H2H is not just a technology upgrade; it’s a governance enabler that turns policies into consistently-executed controls.
- It creates a single control surface across all banks, making evidence collection fast and reliable.
- Partnering with a specialist reduces time-to-value and concentrates scarce IT effort on strategic initiatives rather than maintenance.
- Where are the manual touchpoints in our payment and reconciliation processes, and what risks do they introduce?
- Can we evidence segregation of duties, approval policies, and proof of delivery for every payment?
- How quickly could we adapt to new schemes or bank requirements without compromising control effectiveness?
Next Steps
Book a consultation with AccessPay’s H2H experts. We’ll map your banking estate, identify quick wins in control effectiveness, and outline an implementation plan aligned to the Code.
Download the full white paper: Connected Finance: The Business Case for Host-to-Host Bank Connections in Driving Finance Transformation.
