ESG: New Disclosure Rules For Investment Managers

1. New EU and UK disclosure requirements

The new disclosure requirements for investment managers and advisers¹ with respect to their environmental, social and corporate governance (ESG) policies will apply in the European Union from 10 March 2021². New climate-related disclosures will apply to investment managers in the United Kingdom under a UK disclosures regime that is expected to be phased in from 2022. Although the finer details implementing the new frameworks have not yet been finalised, or in the case of the UK, have not yet been published, it is clear that the EU and the UK have ambitious plans for enhancing ESG disclosure in the financial sector.

We outline below the key provisions under the Sustainable Finance Disclosure Regulation³ (SFDR) and, at a more high level, the Taxonomy Regulation^4,5. We also outline the key principles of the proposed UK mandatory climate-related disclosures regime for investment managers, which will be based on the