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April 2026

PIMFA has responded to the FCA consultation CP25/34: ESG ratings: proposed approach to regulation, on rules to improve transparency and trust in the ESG ratings market.

While broadly agreeing with the proposals and supporting the FCA’s intention to make ESG ratings more transparent and reliable, we also emphasised the need to ensure that information on ESG ratings is provided in a concise, user‑friendly, Consumer Duty‑appropriate format.

As many of our members will need to rely on their own expertise to assess methodologies when conducting due diligence on which rating provider to select, simplicity and clarity in how this information is presented becomes essential.

We also note that the cost–benefit balance for smaller ESG providers may be challenging, and if compliance costs become too high, smaller firms may be pushed out or may choose to move into other parts of the market.

Many of these smaller firms possess valuable niche expertise, and it is important that the FCA offers support during the gateway authorisation process to help them navigate regulatory expectations.

Please read the response here.

Financial markets rely on high-quality and comparable sustainability disclosures to inform asset pricing and capital allocation. Financial institutions, including asset managers, banks, insurers and pension providers, also need reliable data on sustainability factors to build products that meet their clients’ and consumers’ needs. Reliable data also helps with their own investment and risk management processes.

In Q2 2026, the FCA plans to consult on streamlining product-level TCFD reporting requirements. This is part of the ongoing work to consider streamlining the sustainability reporting framework for asset managers and FCA-regulated asset owners. It also reflects the FCA priorities to support growth and be a smarter regulator.

More information can be found at the FCA multi-firm review

March 2026

The FCA has published examples of good and poor practice for using labels under the Sustainability Disclosure Requirements (SDR) regime.

The examples are set out for each of the four labels. Firms have been able to use sustainability labels under the SDR regime since July 2024. The examples published are based on what the FCA has seen through the fund authorisations process for updating pre-contractual disclosures and through the regulator’s engagement with industry stakeholders.

The FCA says that applications to update pre-contractual disclosures have improved, as firms have become more familiar with the requirements. However, it hasn’t always been clear whether or how firms meet the labelling requirements, or whether disclosures accurately reflect what the fund invests in.

Good disclosures are clear, concise, easy to read and understand. They avoid complex terms and duplication and explain those that are open to interpretation, use a consistent narrative and logical flow of information, only disclose information relevant to the fund, use the right label for the fund and meet the relevant requirements, accurately reflect what the product invests in.

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