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Sustainability Disclosure Requirements and Investment Labels

Insight

Sustainable Finances

The FCA recently published its long-anticipated consultation paper on Sustainability Disclosure Requirements (SDR) and Investment Labels (CP22/20). 

The new proposals will primarily affect discretionary managers and fund operators, and include: 

  • A general “anti-greenwashing” rule applicable to all firms. 
  • New investment labels to be used by funds and discretionary strategies who wish to market themselves to consumers as “green” or “sustainable”.
  • A requirement for new consumer-facing disclosures. 
  • Further reporting requirements, designed to enhance the new TCFD-aligned reporting requirements.

In our new briefing on CP22/20, we look at the background and scope of the new proposals. We look in detail at the proposed investment labels and disclosure requirements. We also consider what firms can do now to start preparing for the new rules. 

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If you require further information about anything covered in this briefing, please contact Grania Baird, Jessica Reed, Kya Fear or your usual contact at the firm on +44 (0)20 3375 7000.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.

© Farrer & Co LLP, January 2023

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About the authors

Grania Baird banking lawyer

Grania Baird

Partner

Grania leads the financial services regulatory and funds practice at Farrer & Co. She has over 20 years of experience acting for clients across the sector, including private banks, wealth managers, asset managers and, more recently, payment services firms and Fintech businesses.

Grania leads the financial services regulatory and funds practice at Farrer & Co. She has over 20 years of experience acting for clients across the sector, including private banks, wealth managers, asset managers and, more recently, payment services firms and Fintech businesses.

Email Grania +44 (0)20 3375 7443
Jessica Reed lawyer photo

Jessica Reed

Partner

Jessica is an experienced financial services and funds lawyer. She advises a wide range of clients including asset managers, wealth managers, private banks, international financial institutions and charitable institutions on the full spectrum of contractual, transactional and regulatory issues.

Jessica is an experienced financial services and funds lawyer. She advises a wide range of clients including asset managers, wealth managers, private banks, international financial institutions and charitable institutions on the full spectrum of contractual, transactional and regulatory issues.

Email Jessica +44 (0)20 3375 7518
Kya Fear lawyer photo

Kya Fear

Associate

Kya is an associate in our Banking and Financial Services team providing advice to financial services firms, including, asset managers, wealth managers, private banks, and charitable institutions on a broad range of legal and regulatory issues.  

Kya is an associate in our Banking and Financial Services team providing advice to financial services firms, including, asset managers, wealth managers, private banks, and charitable institutions on a broad range of legal and regulatory issues.  

Email Kya +44 (0)20 3375 7509
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