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ARTICLE · 13 NOVEMBER 2025

ESG Ratings - New Regulated Activity

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

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A draft version of the Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025 (Order) has been published.

United StatesFinance and Banking
Marina Reason
Marina Reason
Kelesi Blundell
Kelesi Blundell
Clive Cunningham
Clive Cunningham
Chris Hurn
Chris Hurn
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A draft version of the Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025 (Order) has been published.

The Order will amend the Regulated Activities Order (RAO) to make the provision of ESG ratings a regulated activity under the Financial Services and Markets Act 2000 (FSMA). This will require providers of ESG ratings to be authorised and supervised by the FCA.

The FCA has issued a statement welcoming this development, which will grant it the legislative powers to regulate ESG ratings providers. The FCA has also confirmed its intention to consult, before the end of this year, on its proposed regime for ESG ratings providers.

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