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ARTICLE · 18 JUNE 2026

FCA Consults On Simplifying Product-level Climate Disclosure Requirements

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

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The FCA has set out proposals to simplify product-level climate disclosure requirements applying to asset managers, life insurers and FCA-regulated pension providers in its latest Quarterly Consultation Paper (No. 52) (CP26/17), published on 5 June 2026.

United KingdomWealth Management

The FCA has set out proposals to simplify product-level climate disclosure requirements applying to asset managers, life insurers and FCA-regulated pension providers in its latest Quarterly Consultation Paper (No. 52) (CP26/17), published on 5 June 2026.

In a move that should lighten the product-level reporting burden on asset managers and asset owners alike, in-scope firms would no longer be required to prepare TCFD product-level reports. Instead, less onerous reporting requirements would apply to communicating with both retail and institutional clients with the FCA pivoting to a less prescriptive, outcomes-based approach.

In the paper, the FCA recognises that TCFD product reports are “too long and complicated” for retail investors to understand and that institutional investors “typically obtain [climate reporting] by engaging directly with firms rather than [via] the public [TCFD product] reports”. 

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