The FCA’s Sustainability Disclosure Requirements (SDR) regime is the UK’s flagship ESG regime, set to apply from May 2024 onwards. The SDR is primarily a product labelling regime which is accompanied by entity-level disclosure requirements, new anti-greenwashing guidance and ESG marketing requirements.
This implementation guide provides a practical overview of the regime and key points for firms to consider when launching an SDR labelled fund and completing entity-level disclosures. Split into six briefing papers, our implementation guide covers:
Introduction, Scope and Application
The FCA’s Anti-Greenwashing Rule
Complying with the Operational Aspects of the SDR
Fund Launch and Distribution Under the SDR
Details on the SDR’s requirements relating to launching and distributing funds.
Disclosure and Fund Naming Rules
An overview of the new disclosure requirements and fund naming rules under the SDR.
This guide also considers the interaction between the SDR and the EU’s Sustainable Finance Disclosure Regulation (SFDR) regime. The FCA received substantive feedback to its consultation on the SDR on the importance of interoperability between the SDR and SFDR regimes, and we explore whether this has been a success.
Other Resources
In case you missed the webinar related to this topic, you can access our ESG Regulatory Evolution in 2024: SDR, SFDR and Beyond Webinar which we hosted in January. Speakers included Caitlin McErlane (Chair), Shaneil Shah, Adam Jacobs-Dean (Managing Director, AIMA) and Tonia Plakhotniuk (Vice President, Climate & ESG Capital Markets of NatWest).
You can also visit our dedicated resource page to access all recordings in our Demystifying ESG Webinar Series.
We hope these briefings will provide useful insight for you. If you have any queries or would like to discuss the contents of the briefings further, please do get in touch with a member of the team.
Author
Caitlin McErlane
Caitlin’s practice focuses on advising a range of global financial institutions on complex and high value regulatory matters. She advises banks, major corporates, payment institutions and asset managers on navigating UK and EU financial services regulation. She has particular experience in advising clients on regulatory implementation projects, day-to-day compliance issues, and regulatory issues arising in the context of large-scale transactions. She also expertise in the areas of banking and wholesale financial markets regulation, in particular in the FX and fixed income space, alongside experience advising market infrastructure providers, including major international exchanges, trading platforms, clearing systems and payment services providers, on a variety of compliance issues.
Caitlin is also a member of the Baker’s ESG and sustainability taskforce, and advises a range of clients on the drafting and implementation of ESG policies and the implications of becoming a signatory to the UNPRI and the Stewardship Code. Caitlin is an authority on regulatory reforms in the sustainability space and sits on a number of trade association working groups. She has recently been interviewed by Climate Action on her work and is a frequent speaker on the subject.
Author
Shaneil Shah
Shaneil provides strategic regulatory advice to clients across the regulated sector, with a particular focus on the regulations applicable to fund managers, investment firms, market infrastructure, banks and insurers. He advises clients throughout their regulatory lifecycle, from pre-authorisation, through to business expansion and on responding to new regulatory developments. Shaneil also advises on contentious matters, including investigations and enforcement proceedings brought by financial regulators, internal regulatory investigations and financial services disputes.
Shaneil has particular experience advising clients on complex regulatory implementation projects, and has worked closely with a number of asset managers to launch novel products for both retail and wholesale investors. He also advises a wide range of clients on developments in ESG regulations, including the EU’s SFDR and Taxonomy Regulations and the UK’s ESG regime.
Shaneil has undertaken secondments to the London branch of a global investment bank (focusing on contentious matters) and to Baker McKenzie in Hong Kong.
