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ARTICLE · 30 NOVEMBER 2023

UK Sustainability Disclosure Requirements – Initial Considerations For UK AIFMs

Proskauer Rose LLP
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On 28 November 2023, the long-awaited UK regime for the labelling, marketing and disclosure of sustainable funds (Sustainability Disclosure Requirements or "SDR") has been published in the Financial Conduct Authority's ("FCA") Policy Statement PS23/16.

United KingdomFinance and Banking
John Verwey
John Verwey
Amar Unadkat
Amar Unadkat
Rachel E. Lowe
Rachel E. Lowe
Michael Singh
Michael Singh
Sulaiman Malik
Sulaiman Malik
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On 28 November 2023, the long-awaited UK regime for the labelling, marketing and disclosure of sustainable funds (Sustainability Disclosure Requirements or "SDR") has been published in the Financial Conduct Authority's ("FCA") Policy Statement PS23/16.

We summarize here initial key considerations for UK AIFMs and AIFs:

  1. Scope covers UK AIFMs and UK AIFs (but not overseas managers/funds or portfolio managers/advisers): both full-scope UK and small authorized UK AIFMs will need to consider various elements of SDR in relation to their (authorized or unauthorized) AIFs. However, those with portfolio management or advisory permissions only will not currently be in scope of SDR's labelling, marketing and disclosure rules, with the FCA noting that it plans to consult on portfolio managers in early 2024 and set up an independent working group to consider the role of advisers. The exception to this is in relation to entity-level TCFD and on-demand product-level TCFD

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