UKSIF is pleased to respond to the Financial Conduct Authority’s CP122/20: Sustainability Disclosure Requirements (SDR) and investment labels consultation.

In formulating our response, UKSIF brought together multiple private roundtables for members to discuss the consultation and the labels, as well as individually speaking to a range of different organisations.

The Consultation proposes three ESG Labels:

• ‘Sustainable Focus’ – products that meet a credible standard of environmental and/or social sustainability, or align with a specified environmental and/or social sustainability theme.
• ‘Sustainable Improvers’ – assets that may not be sustainable now but aim to improve their sustainability over time.
• ‘Sustainable Impact’ – products with the objective to achieve a positive, measurable contribution to sustainable outcomes.

UKSIF is strongly supportive of the proposed approach but sees that there are areas for the FCA to carefully consider tweaking such as the labels’ applicability across a range of asset classes beyond equities, the treatment of fund of funds, and certain aspects of the qualifying criteria, particularly for the ‘Improvers’ category. We remain optimistic that the upcoming regime will contribute to rebuilding trust among savers in sustainable investment choices.

Please feel free to contact Oscar Warwick Thompson, Head of Policy and Communications, at o.warwickthompson@uksif or Heidi Douglas-Osborn, Policy Manager, at heidi.douglas-osborn@uksif.org if you have any further questions.

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