UK: SDRs - Managers with AUM of £5b or more, are you ready for the 2 December entity level reporting deadline?

Under the FCA's Sustainability Disclosure Regime, it has adopted a tiered approach to disclosures, with obligations to produce consumer facing disclosures, product level disclosures and finally, entity level disclosures.

The entity level disclosure rules require UK managers managing a UK UCITS or an AIF (UCITS management companies, relevant UCITS ICVCs, and full-scope or small authorised UK AIFMs) to make annual, entity-level disclosures as part of a "sustainability entity report" (a public report regarding the overall assets managed by a manager in relation to its sustainability in-scope business), unless their assets under management in relation to that sustainability in-scope business are below £5 billion (calculated as a three-year rolling average on an annual assessment).

This disclosure obligation has applied to managers meeting the requirements of an enhanced SMCR firm since 2 December 2025. From 2 December 2026 the obligation extends to all other fund managers meeting the £5bn threshold.

UK managers that are required to make entity-level disclosures will need to disclose the following under ESG 5.6.1 (broadly consistent with the four-pillar approach used under TCFD and the ISSB standards)

• The manager’s approach to governance, with respect to managing sustainability risks and opportunities
• The actual and potential impacts of any material sustainability-related risks and opportunities on the manager’s businesses, strategy and financial planning
• How the manager identifies, assesses and manages sustainability-related risks; 
• The metrics and targets used by the manager to assess and manage relevant material sustainability related risks; 

In addition to the above, the manager will also need to: 

• explain where its approach to a particular investment strategy, asset class or product is materially different to its overall entity-level approach to governance, strategy, risk management or targets and metrics; 
• briefly explain in its sustainability entity report how the manager’s strategy has influenced the decision-making and process by which it delegates functions, selects delegates, and relies on services, strategies or products offered or employed by third parties, including delegates;

Where the manager is required to prepare a TCFD entity report, it must include the contents of that report or hyperlink it within its sustainability entity report.  

What to do now

With the deadline now just weeks away, now is the time to confirm your scoping position, pull together governance, strategy, risk management and metrics/targets information across your sustainability in-scope business, and make sure publication arrangements are ready.

If you'd like our help working through this do get in touch.