Who this is for

We have introduced rules and guidance to help consumers navigate the market for sustainable investment products. 

These are:

See our Policy Statement Sustainability Disclosure Requirements (SDR) and investment labels policy statement[3] (PS23/16) for more information, including Annex 2, which sets out an overview. 

We consulted on extending our SDR and investment labels regime to portfolio management (CP24/8[4]). The consultation closed on 14 June 2024.

How this affects firms

We set out below how firms should consider the regime and, where relevant, take steps ahead of the rules coming into effect. This is not an exhaustive list.  

All authorised firms should: 

UK asset managers should: 

This includes: 

Carrying out associated actions such as:

All distributors should:

More information about what this means for you

We will update the following section to provide clarification to firms on common queries.  

Implementation timeframes

The rules and guidance come into force on the following dates: 

Sustainability disclosure and labelling regime implementation times

Sustainability disclosure and labelling regime implementation times

Download infographic as a PDF[6]

Anti-greenwashing rule

From 31 May 2024, firms need to ensure their sustainability references are fair, clear and not misleading, and proportionate to the sustainability profile of the product and service. However, firms subject to the naming and marketing rules for asset managers aren't required to meet those additional requirements until 2 December 2024.

We've issued guidance[5] which is designed to help firms understand and implement our rules. It includes good and poor practice examples to help firms market their products in the right way.  

Investment labels

We're introducing 4 investment labels for products with sustainability objectives that aim to improve or pursue positive outcomes for the environment and/or society. For a summary of the criteria, see Annex 2 of PS23/16[6]. This section covers responses to some of the common questions we've received so far. It's not exhaustive.

Notifying us about your use of an investment label for a fund

We set out here how to notify us when you are using an investment label.

You will also find details of how to apply to make associated changes to a fund’s name, investment objectives or policy.

The steps for notifying us are outlined below. Please check which of the 4 scenarios applies to you. 

Criteria

Naming and marketing

Firms must ensure they make the necessary changes to meet the naming and marketing requirements by 2 December 2024. If firms are launching new products before this date, they should still be aware of and consider these requirements.

On 9 September 2024, to further help firms to comply with the SDR rules, we announced that we are offering limited temporary flexibility to the naming and marketing rules in exceptional circumstances. 

Read our statement[-14]

Scope 

Firms using sustainability-related terms only need to meet the additional naming and marketing requirements (including on product naming and producing the associated disclosures and statement) in respect of products for retail clients. 

All firms are required to comply with the anti-greenwashing rule and must ensure their sustainability references are fair, clear and not misleading and proportionate to the sustainability profile of the product and service.

Exceptions 

Firms can use sustainability-related terms in other contexts where not referring to sustainability characteristics, for example 'economic climate' or 'financial impact'. 

Another exception is where a firm is only making short, factual, non-promotional statements, for example a statement that it carries out ESG integration on the product as part of its usual risk management process. However, if, for example, ESG integration or another sustainability-related investment approach is being promoted in its marketing as material to the product, the firm will be required to produce a disclosure and statement to clarify why the product doesn’t have a label. 

The purpose of these exceptions is to avoid firms being brought into scope of the rules if they are simply referencing sustainability-related terms in a non-promotional way. The naming and marketing rules are for the use of sustainability-related terms in financial promotions relating to the sustainability characteristics of a particular product. Other materials produced by firms that include sustainability references are likely to be captured by the anti-greenwashing rule.

: Information added December 2024 update on consultation
: Document update Update to pre-contractual disclosure examples.
: Information added Pre-contractual disclosure examples
: Information added Update on temporary flexibility on 'naming and marketing' rules
: Link added firm labels added to page to download
: Information added notifying us about use of an investment label
First published: Last updated: 28/02/2025 See all updates

Source URL: https://www.fca.org.uk/firms/climate-change-and-sustainable-finance/sustainability-disclosure-and-labelling-regime

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