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 making it a specified kind of activity, when that rating is likely to influence a decision to make an investment specified in Part 3 of the RAO.  The Order inserts a new Chapter 15F into the RAO. This chapter defines the scope of the new regulated activity (article 63U) and sets out a number of exclusions (articles 63V to 63Z5), including exclusions for regulated products and services, unregulated benchmarks, unregulated credit ratings, intra-group ratings, private use, ancillary non-commercial provision, public authorities, central banks and international organisations, accreditation or certification, regulatory or legal requirements, and proxy advice.

The Order also includes transitional and savings provisions to allow persons who are within scope of the new regulated activity and have applied for the relevant permission (including variation of pre-existing permission) to continue providing ESG ratings during a limited period following commencement, subject to appropriate conditions and FCA supervision.