09 Nov 2022

FCA CP22/20: Raising the bar to build trust

As envisaged in the Government’s roadmap to greening finance and following its discussion paper DP 21/4 published late last year, the FCA has now published its long-awaited consultation on sustainability disclosure requirements and investment labels for investment products (CP22/20). In this briefing, we provide an overview of the proposals and discuss some of the issues arising from the requirements.

With the exponential growth in investment products marketed as having ESG characteristics, the FCA has been concerned with greenwashing for some time and the impact this could have on shifting capital to  investments which genuinely support transition. As evidenced in the publication of its Guiding Principles for the design, delivery and distribution of ESG funds, the FCA has been clear that any sustainability-related claims must be substantiated.

The consultation seeks to introduce a comprehensive regime covering sustainable investment labels with corresponding eligibility criteria; consumer facing as well as product and entity-level disclosures; naming and marketing rules; and rules for distributors. In the FCA’s own words, it is deliberately seeking to set a “high bar for quality and integrity” when developing the proposed regime.

For the full briefing, please download the publication.


This material is provided for general information only. It does not constitute legal or other professional advice.

Contact Information
Nick Pacheco
Partner at Slaughter and May
Jan Putnis
Partner at Slaughter and May
Roland Turnill
Partner at Slaughter and May
Nick Bonsall
Partner at Slaughter and May
Alfred King
PSL Counsel at Slaughter and May