Simpler And More Streamlined Sustainability Disclosure For UK Private Fund Managers: Taking Stock And Comparing With The EU

On 6 August 2025, the Financial Conduct Authority (FCA) published its multi-firm review (review) of climate reporting by private fund and other asset managers, life insurers, and FCA-regulated pension providers (firms). The review included sample Taskforce on Climate-related Financial Disclosures (TCFD) entity and product reports and engagement with trade associations and firms. The result of the review is that the FCA plans to simplify and streamline its regulatory regime on sustainability disclosure requirements for firms. The simplification and streamlining of reporting and other regulatory processes are part of a broader FCA trend.

In the review, the FCA notes that the current climate reporting rules set out in the Environmental, Social, and Governance sourcebook (ESG sourcebook) have increased firms' consideration of climate risks and supported their integration into decision-making. The FCA, however, observes the following themes of interest:

• There have been lower levels of retail investor engagement, due to the complexity of disclosures and TCFD product reports being difficult to find.
• The TCFD rules are too granular, and some data requirements are challenging (for instance, quantitative data to support forward-looking disclosures) and could be simplified, streamlined, and made more proportionate, particularly as asset managers are required to report under multiple sustainability disclosure regimes.
• Firms and stakeholders have requested to clarify the future of the FCA's TCFD rules and consider international consistency.

The simplification planning will encompass the following, both as set out in the ESG sourcebook:

• the TCFD reporting rules under the December 2021 FCA policy statement PS21/24 on climate-related disclosures by asset managers/asset owners/others; and
• the rules on investment labels (labelling regime) and on the UK Sustainability Disclosure Requirements (SDR) under the November 2023 FCA policy statement (PS 23/16).

These workstreams will also be relevant to the UK government's initiatives on sustainability reporting as a whole. These include the ongoing endorsement of the International Sustainability Standards Board (ISSB) standards via the UK Sustainability Reporting Standards and developments on transition plans. On this, a consultation is first expected for how listed companies will adopt new standards, with streamlining and enhancements for asset managers and UK asset owners to follow.

Because firms must continue to comply with the ESG sourcebook, we have set out in the table below a high-level summary of the various requirements. The table also covers the EU's Sustainable Finance Disclosure Regulation (SFDR), noting that many UK firms are also subject to SFDR when marketing in Europe. We have also presented some comments on how the SDR and labelling regime in the UK and the SFDR requirements interact.

Comparative overview table

You may also be interested in our related recent briefings

Sustainability Disclosure Rules in the UK: Extending the FCA's Regime to Portfolio Managers

Further Reform for UK Private Fund Managers: The Government's Road Map for Growth in Financial Services

Horizon Scan for Private Investment Funds: Key Recent Funds, Legal, and Regulatory Developments to Look Out for in the Coming Months (June 2025)

Gaining Access to UK Pension Investors: Key Questions for Private Fund Managers

Corporate Sustainability Reporting in the EU: Simplification, Decluttering, and Regulatory Burden Reduction Under Omnibus I or Continued Uncertainty?

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