On 1 November 2024, the Financial Conduct Authority (“FCA”) updated its sustainability disclosure and labelling regime website and added detailed examples of pre-contractual disclosures to its Sustainability Disclosure Requirements (“SDR“) guidance. The SDR and investment labels regime enters into force on 2 December 2024 and firms have been able to use investment labels since 31 July 2024, as we have reported here. 

The non-exhaustive examples are based on the FCA’s experience of applications to date and provide firms with a practical insight into the types of information that should be disclosed in the pre-contractual documentation of funds seeking to use sustainability labels on investment products. The examples provided illustrate how firms can effectively communicate their sustainability credentials in a clear and consistent manner, ensuring that these labels align with regulatory expectations and meet transparency standards. The FCA’s guidance aims to standardise sustainability disclosures and reduce the risk of greenwashing. For more information on the FCA’s Anti-Greenwashing Rule, please refer to our overview here.  

For further information, please reach out to UKRegulatory@proskauer.com.

Posted in UK/EU Financial Regulation
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Photo of John Verwey John Verwey

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge…

John Verwey is a Regulatory partner and a member of the Firm’s Private Capital industry group.

John advises on financial services regulatory matters at a national UK and European level. He specializes in advising investment firms, including venture, private equity, credit, and hedge fund managers as well as institutional managers and advisers, on all aspects of the UK and EU regulatory regimes.

Another key area of focus is advising clients in the financial services sector on mergers and acquisitions, re-organisations and associated regulatory approvals.

John represents a variety of clients that range from small start-up fund managers to established global fund advisers and managers. In The Legal 500, John is noted as “an all-rounder who gets into the details and manages client expectations on navigating tricky regulatory requirements”.

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Photo of Andrew Wingfield Andrew Wingfield

Andrew Wingfield is an M&A partner and member of the Private Capital Team.

Andrew undertakes a broad range of domestic and cross-border corporate and commercial work for both corporate and private equity clients, advising on acquisitions and disposals, joint ventures, mergers and public…

Andrew Wingfield is an M&A partner and member of the Private Capital Team.

Andrew undertakes a broad range of domestic and cross-border corporate and commercial work for both corporate and private equity clients, advising on acquisitions and disposals, joint ventures, mergers and public takeovers, flotations and equity capital markets and private equity investment.

Andrew is called upon by financial institutions, private equity houses, management and corporates to lead on complex and high-value transactions. Andrew has a very strong financial institutions practice and has been recognized by Chambers UK and Legal 500 in recent years as the “go-to regulatory M&A lawyer” for regulated institutions such as banks, lenders, payment providers, insurance companies, wealth managers or other financial institutions transactions.

In addition, Andrew is widely recognized as a leading M&A and private equity lawyer. In Chambers UK, Andrew has been noted as “dynamic and commercial” and for providing “tailored, practical advice.” A client told Legal 500, “Andrew Wingfield – best lawyer I ever worked with. Super helpful, goes extra mile where needed.”

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Photo of Rachel Lowe Rachel Lowe

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on…

Rachel E. Lowe is a special regulatory counsel in the Corporate Department and a member of the Private Investment Funds Group.

Rachel advises on financial services regulation specializing in sustainable finance and ESG regulation. She has particular expertise in drafting and advising on the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation. Rachel has also supported with EU MiFID and AIFMD sustainability updates for clients, including from a governance and organizational perspective, as well as providing drafting and training support. She also advises on the Corporate Sustainability Reporting Directive (CSRD), including analysis of its applicability for large international group structures.

From a UK perspective, Rachel supports clients with the TCFD-related requirements in the Financial Conduct Authority’s ESG Sourcebook and is increasingly engaged on the UK’s Sustainability Disclosure Requirements (SDR).

More broadly, Rachel has worked with litigation colleagues to assist clients with understanding and mitigating greenwashing-related legal and regulatory risk.

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Photo of Michael Singh Michael Singh

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms…

Michael is an associate in the Private Funds Group in the Corporate Department.

Michael advises clients on a variety of regulatory issues both from a UK and European perspective. He also helps clients on fund related transactions. His clients include private equity firms, investment managers, FinTech companies and wealth management businesses.

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