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UK: What’s on the ESG horizon for financial services?

The UK financial services regulators have updated their Regulatory Initiatives Grid for April 2025 setting out the UK regulatory pipeline for the next 24 months. 

This follows the postponement of the previous publication, due in May 2024, after the announcement of the General Election, and the interim update last October. The Grid is also available in the form of an interactive dashboard and an Excel spreadsheet.

Key updates in relation to ESG include the following:

2025Sustainability Disclosure Requirements (SDR) and investment labels: The FCA is considering next steps for extending the regime to portfolio management and will provide further information in due course (see our earlier blog posts on the SDR regime here and here).
H1 2025 Endorsement of ISSB disclosure standards: The government will consult on the endorsement of the UK version of the ISSB standards (known as the UK Sustainability Reporting Standards – UK SRS) in H1 2025 (April to June 2025). Once published, the FCA intends to consult on disclosure requirements for UK listed companies in Q3 2025. 
H1 2025Transition Plans: HMT will consult in H1 2025 on the development of transition plans and draft UK Sustainability Reporting Standards (UK SRS), followed in Q3 2025 by an FCA consultation on strengthening expectations for listed issuers' transition plan disclosures, with reference to the TPT Disclosure Framework (see our earlier blog post and transition planning materials for more).
H1 2025ESG ratings regulation: Following the government’s laying of secondary legislation in H1 2025 to bring ESG ratings providers within the FCA regulatory perimeter (see our earlier blog post), the FCA will consult on and finalise their regulatory standards for ESG ratings providers, which will be informed by IOSCO recommendations.
H1 2025Enhancing banks’ and insurers’ approaches to managing climate-related risks: The PRA is consulting on updating the Supervisory Statement 3/19 to consolidate regulatory feedback since 2019 on the management of climate-related risks and to bring the expectations into closer alignment with international standards. Formal engagement is planned for H1 2025.
2025-2026Task Force on Climate-related Financial Disclosures (TCFD) reporting requirements: The FCA will continue to monitor TCFD-aligned disclosures, including those of asset managers (see our earlier blog post on lessons from Year 1 of TCFD reporting).
H1 2025Climate Financial Risk Forum: The CFRF working groups will develop materials on key themes of Adaptation and Climate Financial Resilience (Nature and Short-Term Scenarios), with the possible addition of Transition Finance. These will be published in H2 2025 at the CFRF Symposium event.
Summer 2025Prospectus Regime Reform: Following on from its consultation papers on proposals to simplify the UK’s Prospectus Regime, the FCA is aiming to publish final rules and policy statements in summer 2025 and for them to take effect in early 2026.
2026Stewardship Code: Following a review and consultation in 2024 (see our earlier blog post), the revised Financial Reporting Council’s Stewardship Code will come into effect in 2026.
No timing providedUK Green Taxonomy: The government is assessing the responses received following its consultation on whether and how a UK Green Taxonomy could be additional and complementary to existing sustainable finance policies (see our earlier blog post).  It will publish a response in due course which will set out next steps. If the evidence suggests a green taxonomy would be helpful, then there will be a further consultation on the detail of the framework. 

 

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asset managers & funds, banks & insurers, disclosure & reporting, sustainable finance, climate change & environment, corporates, transition planning & finance, uk, blog posts, trackers & horizon scanning