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August 2025

The FCA has set out the findings and next steps following their review into firms’ climate reporting. Overall, the FCA found that their rules have increased firms’ consideration of climate risks and supported their integration into firms’ decision-making. Firms were more transparent with their clients and consumers but encountered some challenges with the availability of data and consistent, well-developed methodologies.

The FCA has updated their sustainability reporting requirements webpage to clarify how firms in scope of both the Task Force on Climate-related Financial Disclosures (TCFD) and Sustainability Disclosure Requirements (SDR) rules can report efficiently under both regimes. The regulator is also considering how to streamline and enhance the sustainability reporting framework. The FCA wants to:

  • Simplify disclosure requirements and ease unnecessary burdens on firms.
  • Maintain good outcomes for clients and consumers and improve the decision-usefulness of reporting, building on the work of SDR to improve trust and reduce greenwashing.

Promote international alignment and help maintain the UK’s position as a global leader in sustainable finance.

May 2025

The FCA has published its Financial Lives 2024 survey. A total of 17,950 respondents completed the survey. Fieldwork for the survey took place between 5 February 2024 and 16 June 2024, with more (just under 45%) completing the survey in May 2024 than in any other month. Section 6 focuses on attitudes towards, and experiences of, responsible investments. The findings include – In 2024, 54% of those with any investments or a DC pension were interested in investing in responsible investments – down from 63% in 2022. 58% of adults with any investments or a DC pension were aware of responsible investments – not statistically different from 2020.  Importantly, 76% of adults with any investments or a DC pension thought it important to be asked if they wish to invest responsibly when selecting a pension or receiving advice. For adults with any investments or a DC pension who had never chosen to invest responsibly, the main reason given for why they had not were that they felt they didn’t have enough money (22%) or didn’t know enough about it (21%).

The FCA has confirmed that, in light of feedback received to the Consultation Paper 24/8, it is not the right time to finalise rules on extending sustainability disclosure requirements (SDR) to portfolio management.

The regulator has reflected on the feedback received via written responses and stakeholder engagement, and has also taken into account wider regulatory work affecting portfolio managers. Overall, there is broad support for extending SDR to portfolio management, with most respondents agreeing this is an important step toward improving consumer outcomes. However, the FCA wants to take time to carefully consider the challenges and ensure that portfolio managers are positioned to implement the regime effectively before introducing requirements.

The FCA intends to prioritise the forthcoming multi-firm review into model portfolio services (as announced in the Asset Management & Alternatives portfolio letter). The review will focus more broadly on how firms are applying the Consumer Duty to provide confidence that investors are receiving good outcomes from model portfolio services. 

The FCA reminds firms of their obligation to comply with the anti-greenwashing rule, which came into effect on 31 May 2024.

March 2025

The FCA is inviting environmental, social and governance (ESG) ratings providers to complete a voluntary survey – with input from the survey used to inform the FCA’s cost benefit analysis, policy development and future regulation.

The survey was issued to ESG ratings providers on 21 March 2025. The FCA state they encourage firms to respond by 2 May 2025 but ask providers to kindly respond through the link no later than 16 May 2025.

Firms that have not received the survey should notify the FCA.

The response notes concerns about its potential complexity and the ability of consumers to easily understand and use it. 

TCFD-aligned reporting requirements currently apply to listed companies, asset managers and FCA-regulated asset owners. In 2025, the FCA intends to consult on changing requirements for listed companies to refer to new reporting standards developed by the International Sustainability Standards Board (ISSB) and Transition Plan Taskforce (TPT). This is subject to the Government finalising its endorsement of the ISSB standards.

January 2025

On 6 December 2024, the FCA published Quarterly Consultation Paper No 46 (CP24/26), proposing to make amendments to the Environmental, Social and Governance sourcebook. It also proposes to update certain guidance provisions in other related sourcebooks for the purposes of clarifying certain existing rules and giving proper effect to the policy proposals consulted upon in Consultation Paper 22/20 and finalised in Policy Statement 23/16.

We consider the SDR amendments to be mostly sensible given that they simply clarify the existing policy intentions. Our response focuses on sections relevant to our members in their role as distributors.

June 2025

The Financial Reporting Council (FRC) has published the UK Stewardship Code 2026, an updated set of principles which offers a framework for reporting that demonstrates high quality stewardship to support economic growth and investment. The new Code takes effect from 1 January 2026 and aims to support long-term sustainable value creation while significantly reducing the reporting burden for signatories.

The UK Stewardship Code has established itself as a global benchmark for best practice in stewardship, driving transparency and accountability in the investment chain. It currently has nearly 300 signatories who represent around £50 trillion in assets under management (AUM).

Key features of the UK Stewardship Code 2026:

  • Enhanced definition of stewardship: The updated definition focuses on the principle of stewardship as the creation of long-term sustainable value for clients and beneficiaries.
  • Reduced reporting burden: The Code features fewer Principles and shorter ‘how to report’ prompts instead of detailed reporting expectations, helping to eliminate ‘box-ticking’ approaches to reporting against the principles. Early evidence suggests signatories may be able to reduce reporting volume by 20-30% while maintaining quality.
  • Flexible reporting structure: Signatories can submit separate Policy and Context Disclosures and Activities and Outcomes Reports or combine them into a single document. The Policy and Context Disclosure will only need to be submitted once every four years.
  • Targeted Principles: The Code now includes dedicated Principles for different types of signatories, including asset owners, asset managers, and for the first time, specific Principles for proxy advisors, investment consultants, and engagement service providers.
  • New guidance: Optional guidance will provide useful tips and examples to support effective implementation, particularly for those managing non-equity asset classes.

To support signatories in adapting to the new Code, 2026 will serve as a transition year. During this period, no existing signatories will be removed from the signatory list following their 2026 application. This will allow current signatories to familiarise themselves with the new format and use it as a platform to explain their individual approach to stewardship.

April 2025

The FCA has updated its webpage following feedback received to its Discussion Paper Finance for positive sustainable change (DP 23/1, February 2023) in which the regulator asked for views on sustainability-related governance, incentives and competence in regulated firms.

The responses received were generally positive about the importance of sustainability matters and the role of the themes outlined in DP23/1. Respondents broadly agreed that integration and alignment are important factors in the successful delivery of firms’ sustainability strategies. Respondents noted it is important that firms clearly articulate the purpose underpinning their approaches, which should in turn be reflected in the tone from the top.

But many respondents said that some of the DP’s themes, particularly around culture, are less suited to formal rules, which could risk being overly prescriptive and leading to tick-box approaches. Since publishing DP23/1, the FCA has introduced rules relating to some of the themes. The Consumer Duty came into force on 31 July 2023; SDR and labelling rules were published on 28 November 2023 and the Anti-Greenwashing Rule came into effect on 31 May 2024. The FCA recognises the importance of allowing time for new measures to be implemented before introducing further rules in these areas.

The regulator is not currently considering introducing new rules on the themes discussed in DP23/1. But the DP’s themes remain important to firms’ success in embedding sustainability considerations, delivering value to consumers and supporting market integrity.  The FCA will continue to promote the themes discussed in DP23/1 through other initiatives, both domestically and internationally.

February 2025

In December 2024 the FCA consulted on amendments to the Environmental, Social and Governance (ESG) sourcebook and certain guidance provisions in other related sourcebooks for the purposes of clarifying certain existing rules and giving proper effect to the policy proposals consulted upon in CP22/20 and finalised in PS23/16.

The regulator has now finalised these changes in Handbook Notice No 127. The amendments aim to increase transparency of the sustainability goals and features of products and reduce the risk of harm from greenwashing. They also advance the consumer protection objective, providing transparency and clarity to investors who wish to invest in sustainable products, and the integrity objective, helping to provide structure to a complex market for sustainable investment products.

In November 2024 the Financial Reporting Council (FRC) issued a consultation on updates to the UK Stewardship Code.

The consultation follows on from updates to the UK Stewardship Code set out in July 2024 and sets out proposals such as a revised and enhanced definition of stewardship and a streamlined reporting process separating policy and activity disclosures to reduce reporting burdens.

November 2024

On 14 November 2024 HM Treasury issued a consultation on a UK Green Taxonomy, with the purpose of supporting investment into activities aligned with sustainability goals, and mitigating greenwashing.

The consultation is seeking views on whether a UK Green Taxonomy would be additional and complementary to existing sustainable finance policies, including in supporting market participants to make sustainable investment decisions, and the specific market and regulatory use cases which facilitate this. 

In addition to developing a clear understanding of the use cases, the government is also seeking feedback on how to maximise the usability of a UK Taxonomy, should respondents support taking one forward. This includes considering key design features that will impact the overall usability of a UK Taxonomy.

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