How to Write a Holding Statement

What Is a Holding Statement?

A holding statement is an initial public response issued when a crisis emerges but full details aren't yet available. It acknowledges the situation, demonstrates that leadership is engaged, and buys time for proper investigation without leaving a communication vacuum that others will fill.

For listed companies, holding statements serve additional purposes. They can help manage market expectations, satisfy initial regulatory notification requirements, and provide a baseline for more detailed communications to follow. A well-crafted holding statement positions you as proactively transparent rather than reactive and defensive.

The challenge is balancing speed with accuracy. You need to say something before speculation and rumour take hold. But you can't say things that later prove incorrect. This tension is at the heart of effective holding statement development.

When to Issue a Holding Statement

Not every problem requires a holding statement. The decision depends on several factors including visibility, stakeholder impact, and regulatory requirements.

Issue a holding statement when:

• The issue is already public or will become public imminently
• Stakeholders are actively seeking information
• Silence would be interpreted as evasion or indifference
• Regulatory disclosure may be required
• The issue affects share price or trading decisions
• Media are making enquiries

For listed companies, the threshold is typically lower than for private organisations. Market sensitivity means even moderate issues might warrant statements that private companies would handle internally.

Key Elements of an Effective Holding Statement

Effective holding statements share common structural elements. Including these elements ensures you address stakeholder needs while maintaining appropriate caution about unconfirmed details.

Not every holding statement needs every element. A minor operational issue might not require expressions of concern. A purely financial matter might not involve external authorities. Adapt the structure to your specific situation.

What to Include and Avoid

The most common holding statement mistakes involve saying too much, too definitively, too early.

Include:

1. Confirmation that you're aware of the situation
2. General description of what you're doing in response
3. Appropriate expressions of concern where people are affected
4. Commitment to provide updates
5. Contact information for further enquiries

Avoid:

1. Speculation about causes before investigation completes
2. Blame assignment before facts are established
3. Specific numbers or details that might need correction
4. Defensive language that appears to minimise legitimate concerns
5. Promises you're not certain you can keep
6. Legal language that sounds evasive to non-lawyers

The phrase "no comment" should almost never appear. It suggests you're hiding something even when you're simply being appropriately cautious. Better to explain why you can't say more: "We're not in a position to share further details while the investigation is ongoing."

Holding Statement Templates

Pre-approved templates accelerate response time. Having frameworks ready means you're adapting proven language rather than drafting from scratch under pressure.

Operational incident template:

"[Company] is aware of [brief factual description of incident]. We are working urgently to [contain/address/resolve] the situation and understand its full scope. [If people affected: Our immediate priority is the safety and wellbeing of those affected.] We will provide further updates as more information becomes available. Media enquiries should be directed to [contact]."

Regulatory investigation template:

"[Company] confirms it has been contacted by [authority] regarding [general subject matter]. We are cooperating fully with the [investigation/enquiry]. It would not be appropriate to comment further at this stage, but we will update the market as required. [If applicable: The company maintains that it has acted properly at all times.]"

Data breach template:

"[Company] has identified a [security incident/data breach] affecting [general scope]. We have taken immediate steps to secure our systems and are working with [cyber security experts/authorities] to investigate the incident. We are in the process of notifying affected [customers/stakeholders] directly. Further information will be provided as our investigation progresses."

Channel Considerations

Holding statements may need adaptation for different channels. A formal RNS announcement reads differently from a social media post, even when conveying the same essential message.

For listed companies, consider these channel variations:

• RNS/Exchange: Formal language, regulatory compliance focus
• Press release: More contextual, quotable executive statement
• Website: Accessible language, links to further information
• Social media: Concise, human, with pointer to fuller statement
• Internal: More detail on employee implications and actions

Consistency across channels is critical. Different tone is acceptable. Different facts are not. Ensure all versions convey the same essential information.

From Holding Statement to Full Response

A holding statement buys time. It doesn't resolve the communication challenge. You need a plan for following up with fuller information as it becomes available.

Best practice is to include timing expectations in your holding statement. "We expect to provide a further update by [time/date]" creates accountability. If you can't meet that commitment, issue a brief update explaining why and setting new expectations.

The transition from holding statement to substantive response is where many companies stumble. They issue a reasonable initial statement, then go silent for too long. Stakeholders who were patient after your holding statement become frustrated and suspicious.

Maintain communication momentum even when you have little new to say. "Our investigation is ongoing and we don't yet have additional information to share. We expect to have more to say by [date]" is better than silence.

Pre-Approval and Readiness

The time to develop holding statements is before you need them. Work with legal and compliance teams to pre-approve template language for likely scenarios. This removes a significant bottleneck from crisis response.

Store approved templates where the crisis team can access them immediately, regardless of when a crisis occurs. Include guidance on adaptation parameters, so people know what can be changed without requiring additional approval.

Our team at Corpcast helps listed companies develop comprehensive crisis communication frameworks, including holding statement templates tailored to their specific risk profiles. Contact hello@corpcast.co.uk to discuss your requirements.