FIS Horizons 2023 Brochure - Riding the wave - Flipbook - Page 6
UK/EU ESG
sustainability-related
disclosure rules
Rita Hunter
Partner, London
Julia Cripps
Associate, London
Melanie Johnson
Senior Knowledge Lawyer, London
The long-awaited proposed rules (CP22/20) from the UK financial services
conduct regulator, the Financial Conduct Authority (FCA), were finally
published in Q4 2022.
These set out the proposals for the UK’s
sustainability-related disclosure requirements
and investment-labelling regime (SDR). The
labelling regime aims to help consumers
distinguish between products on the basis of
their sustainability characteristics, themes and
outcomes, and helps them to identify different
types of sustainable investment product and
will be applicable to investment products
marketed in the UK, provisionally from 30
June 2024. The FCA is expected to finalise the
SDR and publish a policy statement by the end
of H1 2023.
The FCA’s classification and labelling of
investment products is a key contrast in
approach to the European authorities who
have made it clear that the EU’s equivalent to
the SDR is “not a labelling regime”.
The EU was the first jurisdiction to announce
its plans for sustainability-related disclosures.
The EU’s Sustainable Finance Disclosure
Regulation (SFDR) which has been phased in
since March 2021 introduced three categories
of products with respective disclosure
requirements. Whilst not intended as such,
these categories have become a de facto
classification and labelling system.
