Client note - FCA’s ESG climate related disclosures proposals
A client note for asset managers summarising the key elements of FCA’s proposed disclosure obligations based on recommendations published by the TFCD.
On 22 June 2021, the FCA published its long-awaited consultation paper, CP21/17 on climate-related disclosures by asset managers.
The new disclosure obligations will be based on recommendations published by the Task Force on Climate-related Financial Disclosures (TCFD).
The consultation is a significant development in the UK ESG regulatory landscape and creates material new obligations for groups with UK regulated asset management entities.
Our client briefing note summarises the top 10 things that asset managers need to know about these important proposals and looks at the following issues
- What is the TCFD and what is the purpose of the FCA consultation?
- How will the FCA implement the TCFD Recommendations into the UK regulatory regime?
- Which firms and products will be subject to the new rules?
- Are non-UK firms going to be subject to the new rules?
- When will the new rules come into force?
- What disclosures must be included in the entity report?
- What disclosures must be included in the product-level or portfolio-level report?
- Is there a mandatory format for the reports?
- Can firms rely on disclosures made in other documents or made by affiliates or delegates?
- How do the UK proposals differ from the EU SFDR?

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