On 10 September 2025, the FCA published its Quarterly Consultation Paper (CP25/24), which (among other things) proposes making minor amendments to the ESG Sourcebook of the FCA Handbook.
The FCA’s key proposals are as follows:
- allowing firms to prepare and publish sustainability product reports which either cover a reporting period of less than 12 months or which include a period of time during which neither a label nor specified terms were used, thereby allowing firms to align sustainability product reports with other relevant reports (e.g. TCFD reports);
- deleting ESG 5.4.8R, which requires firms to use the most recent calculation date within the 12-month reporting period;
- removing reference to “12-month reporting periods under ESGS 5.4.8R” and clarifying that firms are not required to produce on-demand sustainability product reports until at least 16 months after the first use of a label or specified terms; and
- adding guidance to clarify how managers of sustainability products that are index-tracking can meet SDR rules.
CP25/24 is open for public consultation until 15 October 2025. If you would like us to assist with responding to the consultation, please get in touch.
