On 12 October 2026, the European Securities and Markets Authority (“ESMA”) published its third and fourth thematic note on making clear, fair and not misleading sustainability-related claims to address greenwashing risks. These two additional notes focus on impact claims and climate transition claims (the “Thematic Notes”). The Thematic Notes follow previous
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 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.
Green Claims, Real Consequences: What the EU’s New Greenwashing Rules Mean for Businesses
Since 27 September 2026, businesses selling to consumers in the European Union (“EU”) have been subject to new rules on environmental claims. The rules come from the EU’s Empowering Consumers for the Green Transition Directive (EU) 2024/825 (the “EmpCo Directive”), which amends the Unfair Commercial Practices Directive (2005/29/EC) (“UCPD”)…
FinReg Monthly Update
Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK, EU and US financial services regulation.
Key Developments in September 2026:
United Kingdom
General Financial Services – Cross Sector
25 September – FCA Handbook: The FCA has published Handbook Notice 144, which sets out changes to the FCA Handbook made…
Parliament’s Position on SFDR 2.0
On 10 September 2026, the European Parliament’s Committee on Economic and Monetary Affairs (“ECON”) has adopted its position on the reform of the Sustainable Finance Disclosure Regulation (“SFDR”), marking a significant milestone in the SFDR 2.0 legislative process. The position is expected to be endorsed by the European Parliament (the “…
FinReg Monthly Update
Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK, EU and international financial services regulation.
Key Developments in July 2026:
United Kingdom
General Financial Services – Cross Sector
31 July – FCA Handbook: The FCA has published Handbook Notice 143, which sets out changes to the FCA Handbook made…
FCA remuneration reform: what private capital investors need to know
The FCA’s proposed overhaul of the remuneration rules is relevant not only to regulated firms, but also to private capital investors buying, financing or selling them.
CP26/27 would replace the separate MIFIDPRU, AIFM and UCITS remuneration codes with a single regime. It would also remove much of the prescription around deferral, malus and clawback, guaranteed…
SFDR 2.0: Where the Reform Stands
The EU institutions agree that SFDR should move away from Articles 8 and 9 towards three product categories. They remain divided, however, on two questions that matter particularly to private markets: fossil fuel exposure and an exemption for alternative investment funds offered exclusively to professional investors.
Where the process stands
The European Commission published its…
Next steps for Non-EU Groups in Scope of the CSRD
On 23 July 2026, EFRAG published an “Exposure Draft“ of the proposed sustainability reporting standards for certain non-EU undertakings under Article 40a of the Accounting Directive, known as the “ESRS-40a Standards”. The Exposure Draft sets out how in-scope non-EU groups would report under the CSRD framework. We summarise the key points below.
1…
FCA and HM Treasury Publish Detailed Proposals to Streamline UK Asset Management Regulation
On 14 July 2026, HM Treasury published the draft Alternative Investment Fund Managers Regulations 2026 (the “Draft AIFM Regulations”) and an accompanying policy note (the “HMT Policy Note”), setting out proposed legislative changes to the UK AIFM framework. On the same day, the Financial Conduct Authority (“FCA”) published three consultation papers designed to streamline the…
FinReg Monthly Update
Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK, EU and international financial services regulation.
Key Developments in June 2026:
United Kingdom
General Financial Services – Cross Sector
29 June – Consumer Duty: The FCA has published a consultation paper (CP26/23) on changes to the scope and proportionality of the…