In November 2021, the FCA launched a discussion paper “DP21/4: Sustainability Disclosure Requirements (SDR) and investment labels” and sought responses both to the paper itself and the questions laid out in its annex. The discussion paper explored proposals, which are scheduled for consultation in Q2 2022, on the implementation of SDR disclosure requirements for asset managers and certain FCA-regulated asset owners as well as sustainable investment labels, with the aim of building more trust in the market, enhancing transparency in the interests of consumers and meeting certain information needs of institutional investors.
In January 2022, the Impact Investing Institute hosted a roundtable with the FCA to explore the proposals laid out by the discussion paper. The roundtable focused on impact labelling, the tiered structure approach, and the transition category.
We then summarised our key recommendations which emerged from the roundtable in a follow up note to the FCA. Our recommendations focused on six key areas:
- High-level features of impact investing
- General approach – tiered structure and labels
- The “Transitioning” category
- “Responsible” criteria
- Disclosures
- Scope
You can read the full note below.