FCA Issues Updates on ESG Integration and Disclosure Requirements
The Financial Conduct Authority (FCA) provided an update on its discussion paper on sustainability disclosure requirements and investment labels and published its response to the exposure drafts of the International Sustainability Standards Board (ISSB) on general sustainability-related disclosure requirements and climate-related disclosure requirements. Additionally, FCA published the feedback statement on the environmental, social, and governance (ESG) integration in the capital markets in the UK.
Discussion paper on sustainability disclosure requirements and investment labels. FCA announced that its discussion paper (DP21/4) on sustainability disclosure requirements and investment labels has now been closed for comments. With the discussion paper, FCA wanted to gather views on the new sustainability disclosure requirements for asset managers and the FCA-regulated asset owners as well as a new classification and labeling system for sustainable investment products. Feedback on the discussion paper will help FCA develop its proposed rules. Initially, FCA had aimed to consult on the proposed rules in the second quarter of 2022; however, it is now planning on consulting in the Autumn, allowing it to take account of the other international policy initiatives and ensure that stakeholders have time to consider these issues.
Response to ISSB exposure drafts. FCA published its response to the exposure drafts on general requirements for disclosure of sustainability-related financial information (IFRS S1) and climate-related disclosures (IFRS S2). FCA welcomes the exposure drafts published by the International Sustainability Standards Board (ISSB) in March 2022. However, FCA highlighted some targeted matters for consideration by ISSB. These emphasize steps that ISSB could consider to encourage widespread adoption of the baseline standards internationally—including by recognizing the different levels of familiarity with and maturity in climate—and sustainability reporting across corporates in different jurisdictions. Addressing these matters could help to mitigate implementation challenges and, therefore, further enhance the effectiveness of the global baseline. For instance, FCA encourages ISSB to consider refining certain definitions, developing guidance to improve the consistency of implementation by preparers, and providing for limited flexibilities and scaling and phasing of requirements, while upholding the welcome ambition of the proposals. FCA also notes the importance of interoperability and encourages ISSB to consider providing examples to demonstrate how the standards act as a global baseline that can interoperate effectively with additional jurisdiction-specific requirements via a “building blocks” approach.
Feedback statement on ESG integration in UK capital markets. FCA published the feedback statement (FS22/4) to its discussion chapter (in consultation paper CP21/18) on environmental, social and governance (ESG) integration in the capital markets in UK. The feedback statement brings together respondents’ views and sets out FCA’s policy response and potential next steps. FCA sets out its policy actions related to the bond frameworks and prospectuses, the voluntary adoption of existing industry standards, the oversight of verifiers and second-party opinion providers, and the ESG data and rating providers. In CP21/18, which was published in June 2021, FCA included a discussion chapter (Chapter 4) on the ESG integration in UK capital markets. In the discussion chapter, FCA had requested feedback on the potential harms that may require policy intervention and on actions that FCA could take to enhance market effectiveness and promote a sound ESG data ecosystem. FCA sought views on issues related to the green, social, sustainability, and sustainability-linked debt instruments (ESG-labeled debt instruments) and the ESG data and rating providers. Along with the feedback statement, FCA published a Primary Market Bulletin 41, which elaborates on its response to the feedback received on the discussion chapter. The Bulletin covers important issues related to ESG-labeled debt instruments. As mentioned in the Bulletin, FCA:
- encourages issuers of ESG-labelled Use of Proceeds debt instruments to consider voluntarily applying or adopting relevant industry standards
- reminds issuers, their advisors, and other relevant market participants of their existing obligation to ensure any advertisement is not inaccurate or misleading and is consistent with the information contained in the prospectus
- encourages issuers and their advisors to consider verifiers’ and assurance providers’ expertise and professional standards and to engage with second party opinion providers and verifiers who adhere to appropriate standards of professional conduct
Related Links
- Discussion Paper on Sustainability Disclosure Requirements
- FCA Response to ISSB Exposure Drafts (PDF)
- Feedback Statement on ESG Integration in UK Capital Markets
- Primary Market Bulletin
Keywords: Europe, UK, Banking, Securities, ESG, Climate Change Risk, Disclosures, Sustainability-Related Disclosures, Sustainable Finance, Debt Instruments, ISSB, FCA
Featured Experts

James Partridge
Credit analytics expert helping clients understand, develop, and implement credit models for origination, monitoring, and regulatory reporting.
Hasan Cerhozi
Hasan leads Moody’s Analytics ESG methodology development. He is expert on carbon transition, nature related risks and is a guest lecturer at ESSEC Business school on sustainable finance.

Michael Denton, PhD, PE
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
Previous Article
EIOPA Welcomes the Proposed Artificial Intelligence ActRelated Articles
ISSB Sustainability Standards Expected to Become Global Baseline
The finalization of the two sustainability disclosure standards—IFRS S1 and IFRS S2—is expected to be a significant step forward in the harmonization of sustainability disclosures worldwide.
IOSCO, BIS, and FSB to Intensify Focus on Decentralized Finance
Decentralized finance (DeFi) is expected to increase in prominence, finding traction in use cases such as lending, trading, and investing, without the intermediation of traditional financial institutions.
BCBS Assesses NSFR and Large Exposures Rules in US
The Basel Committee on Banking Supervision (BCBS) published reports that assessed the overall implementation of the net stable funding ratio (NSFR) and the large exposures rules in the U.S.
Global Agencies Focus on ESG Data, Climate Litigation and Nature Risks
At the global level, supervisory efforts are increasingly focused on addressing climate risks via better quality data and innovative use of technologies such as generative artificial intelligence (AI) and blockchain.
ISSB Standards Shine Spotlight on Comparability of ESG Disclosures
The finalization of the IFRS sustainability disclosure standards in late June 2023 has brought to the forefront the themes of the harmonization of sustainability disclosures
EBA Issues Several Regulatory and Reporting Updates for Banks
The European Banking Authority (EBA) recently issued several regulatory publications impacting the banking sector.
BCBS Proposes to Revise Core Principles for Banking Supervision
The Basel Committee on Banking Supervision (BCBS) launched a consultation on revisions to the core principles for effective banking supervision, with the comment period ending on October 06, 2023.
US Proposes Final Basel Rules, Transition Period to Start in July 2025
The U.S. banking agencies (FDIC, FED, and OCC) recently proposed rules implementing the final Basel III reforms, also known as the Basel III Endgame.
FSB Report Outlines Next Steps for Climate Risk Roadmap
The Financial Stability Board (FSB) recently published the second annual progress report on the July 2021 roadmap to address climate-related financial risks.
EBA Plans on Ad-hoc ESG Data Collection and Climate Scenario Exercise
The recognition of climate change as a systemic risk to the global economy has further intensified regulatory and supervisory focus on monitoring of the environmental, social, and governance (ESG) risks.