Sustainability Disclosure Requirements and Investment Labels

Sustainable finance regulation

Grania Baird

Jessica Reed

Kya Fear

The FCA recently published its long-anticipated consultation paper on Sustainability Disclosure Requirements (SDR) and Investment Labels (CP22/20).

The new proposals will primarily affect discretionary managers and fund operators, and include:

  • A general “anti-greenwashing” rule applicable to all firms.
  • New investment labels to be used by funds and discretionary strategies who wish to market themselves to consumers as “green” or “sustainable”.
  • A requirement for new consumer-facing disclosures.
  • Further reporting requirements, designed to enhance the new TCFD-aligned reporting requirements.

In our new briefing on CP22/20, we look at the background and scope of the new proposals. We look in detail at the proposed investment labels and disclosure requirements. We also consider what firms can do now to start preparing for the new rules.


If you require further information about anything covered in this briefing, please contact Grania BairdJessica ReedKya Fear or your usual contact at the firm on +44 (0)20 3375 7000.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.

© Farrer & Co LLP, January 2023

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