What if the UK doesn’t implement the SFDR? A client note

The European and global financial services industry is working hard to ensure compliance with the EU Sustainable Finance Disclosures Regulation (SFDR), a key pillar of the EU's ESG initiative.

However, some UK firms are now re-examining their prior assumptions that SFDR would be implemented into UK domestic law.

On the back of many discussions on this complex topic with our clients and contacts across the industry, we have produced a briefing note in which to share our thoughts more widely.

In the note we set out:

• the current legal position on whether and how SFDR could become part of UK law;
• a summary of the consequences for UK firms (who may currently be assuming that SFDR will directly apply to them) should SFDR not become UK law; and
• several practical scenarios to illustrate how SFDR could still be relevant for UK firms (particularly those doing certain types of cross-border business into the EU).