Navigating ESG issues during the private fundraising process
UK SDR
Labelling regime
Customer
disclosures
Sustainability
reporting
Anti-greenwashing
rule
Distributor rules
Scope
UK fund managers that manage
UK funds
UK fund managers that manage
UK funds
UK fund managers that manage
UK funds which meet certain
AUM thresholds (see
"implementation timetable")
All FCA-authorised firms; all
products and services (both
retail and professional)
FCA-authorised firms
distributing recognized funds to
retail investors
Requirements
Four opt-in sustainable labels focusing on various
ESG investment strategies, comprised of
"sustainable focus", "sustainable improvers",
"sustainable impact" and "sustainable mixed goals".
Consumer-facing disclosures (summarising how the
product will pursue and measure the sustainability
objectives) and pre-contractual disclosures (with
more detailed information on the product's
sustainability profile.
Entity-level report focusing on the manager's
sustainability-related risks and opportunities,
focusing on governance, strategy, risk
management, and metrics & targets (as under the
TCFD framework).
All claims made about the sustainability
characteristics of a product or service must be clear,
fair and not misleading.
Disclosures when distributing UK funds that have a
sustainable label or notices for certain overseas
funds that use ESG terms.
Implementation timetable
31 July 2024
31 July 2024
December 2, 2025 (largest
managers: £50bn or more AUM)
December 2, 2026 (smaller
Managers: £5bn-50bn AUM)
31 May 2024
31 July 2024 (labelled funds)
2 December 2024 (overseas funds)
ROPES & GRAY
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