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Next steps on Sustainability Disclosure Requirements: Implementation Update 2024

23 May 2024

Cristian Echavarria, Principal

On May 16 2024, the UK Government released an update regarding the development of the economy-wide Sustainability Disclosure Requirements (“SDR”). This update provides a series of next steps for the application of these requirements, covering corporate disclosures, financial product information, transition plan disclosures, and taxonomy disclosures.

Key updates include:

UK Sustainability Reporting Standards (“SRS”):

  • The Government plans to introduce ISSB-aligned UK SRS by Q1 2025.
  • The FCA will require UK-listed companies to disclose against these standards.
  • Consideration of similar obligations for non-listed companies is underway.
  • Changes will be effective for accounting periods starting on or after January 1 2026.

Transition Plan Disclosures:

  • The Transition Plan Taskforce (“TPT”) is developing the TPT Disclosure Framework.
  • This framework supports companies in reporting on their plans and achieving net-zero goals
  • The FCA will consult on how transition plans should be disclosed under the UK SRS, referencing the TPT framework.
  • Consultation on disclosure requirements for large UK companies’ transition plans is expected soon.

SDR and investment labels regime:

  • The FCA aims to broaden its scope to include UK portfolio managers; a consultation paper was published recently regarding how the regime will apply to portfolios.
  • The Government will also consult on whether to broaden the scope of SDR to include funds under the Overseas Funds Regime. The Government intends to issue this consultation in Q3 2024.

UK Green Taxonomy:

  • The proposed UK Green Taxonomy is still in development, but the Government reiterated its commitment to deliver.
  • Voluntary disclosures will undergo a testing period of at least two reporting years before exploring mandating disclosures.

Nature-related disclosures

  • The Government highlighted its support of initiatives like the Taskforce on Nature related Financial Disclosures (“TNFD”) and encouraged institutions to engage in the TNFD UK National Consultation Group and consider the recommendations.

If you wish to discuss any of the above with one of our experts: