On 29 March 2023, the FCA announced updates on its Sustainability Disclosure Requirements (SDR) and investment labels consultation, including feedback on the proposals and planned timings for the Policy Statement.

Due to the “significant response” received to the consultation, the FCA intends to publish the Policy Statement in Q3 2023, and the proposed effective dates will be adjusted accordingly.

The FCA says it is carefully considering the feedback to ensure that first and foremost the regime protects consumers but also recognises and takes account of any practical challenges that firms may have. This includes, but is not limited to, considering the approach to the marketing restrictions, refining some of the specific criteria for the labels and clarifying how different products, asset classes and strategies can qualify for a label, including multi-asset and blended strategies.

Furthermore, when the Policy Statement is published, the FCA will also clarify matters such as that primary and secondary channels for achieving sustainability outcomes are not prescribed, and that the FCA does not require independent verification of product categorisation to qualify for a label. In addition, there will be a place for all in-scope products within the overall package of measures. This includes products that may not qualify for a label but do have some sustainability-related characteristics.

Finally, the FCA confirms that it has sought international coherence with other regimes and will continue to consider how to further support compatibility, while emphasising the need for robust standards so that the UK remains at the “global forefront” of sustainable investment. It will continue to engage with its Disclosures and Labels Advisory Group and other stakeholders, including consumer groups.