ESG and D&I

On 18 December 2025, there was published on legislation.gov.uk The Financial Services and Markets Act 2000 (Regulated Activities) (ESG Ratings) Order 2025 together with an explanatory memorandum.

This Order brings the provision of an ESG rating into regulation under the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO), by

ESG may have been overtaken on the board agenda in recent times by other threats perhaps perceived to be more pressing and against a wider economic and political backdrop in which many have been placing greater emphasis on growth and opportunity. This may have the effect of understating the level of risk posed to businesses

On 12 December 2025, the Financial Conduct Authority (FCA) published its final guidance on non‑financial misconduct (NFM) in financial services in Policy Statement PS25/23. In summary, the FCA is:

(i) amending its Code of Conduct (COCON) sourcebook to explain how NFM can be a breach of the conduct

On 3 December 2025, the Prudential Regulation Authority (PRA) published Policy Statement 25/25: Enhancing banks’ and insurers’ approaches to managing climate-related risks – Update to SS3/19 (PS25/25).

Background

In PS25/25 the PRA provides feedback to the responses it received to Consultation Paper 10/25:  Enhancing banks’ and insurers’ approaches to managing climate-related

In a written response to a request from the Treasury Select Committee, the FCA has provided an update on its programme of work to address non‑financial misconduct (NFM), making it clear that the firm and its managers may also be held responsible in the event of bad behaviour anywhere in the ranks.

With

On 18 August 2025, the Transition Finance Council issued a consultation on draft entity-level Transition Finance Guidelines (the draft Guidelines), which aim to address the current absence of a consistent framework capable of application across asset classes for identifying and evaluating credible transition finance at entity-level.

Background

The draft Guidelines would be voluntary and

On 14 August 2025, the Financial Conduct Authority (FCA) published a follow up letter to share insight from its ongoing engagement with banks active in the sustainability-linked loans (SLLs) market.

Since the FCA’s previous letter in 2023, which highlighted concerns on market integrity, credibility, incentives and conflicts of interest, the FCA

On 6 August 2025, the Financial Conduct Authority (FCA) published its findings following a multi-firm review of firms’ climate reporting in line with its rules.

Background

In 2021, the FCA finalised its new environmental, social and governance (ESG) sourcebook, requiring asset managers, life insurers and FCA-regulated pension providers to disclose climate-related