• Deborah

On December 17, the UK Financial Conduct Authority (FCA) published Policy Statement (PS), PS21/24 Enhancing climate-related disclosure requirements for asset managers and other FCA-regulated entities. This follows its public consultation on the subject in June 2022, (read our summary) as well as the release of a separate Discussion Paper on sustainability disclosure requirements and investment labels published in November 2021 (read our summary here).


Based on the Recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD), the PS sets out final rules and guidance relating to the requirements under a new climate-related disclosure regime for asset managers as well as “asset owners” (i.e., life insurers and FCA-regulated pension providers).

Key highlights of the new rules include, amongst others, requirements relating to:

  • Data availability and use of proxies/assumptions

  • Core metrics and calculation methodologies

  • On demand disclosures and underlying data to clients

  • Scope – entity level

  • Scope – product level

The PS applies directly to entities such as asset managers but will be of interest for other entities such as trustees.


The new rules are applicable since 1 January 2022 for the largest in-scope firms and will be applicable 1 year later for smaller firms above the £5 billion exemption threshold.

The first public disclosures must be made by 30 June 2023.


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