Last week, we wrote about an upcoming deadline for new fund name and marketing rules under the UK FCA’s Sustainability Disclosure Regulation (SDR). The deadline for the rules, set to take effect on December 2, has now been extended until April 2, 2025. However, funds hoping to take advantage of the extension will have to submit an application to the FCA by October 1, 2024. A recent memo from Linklaters gives the details:
“The FCA has updated its website this morning with a statement offering limited temporary flexibility, until 5pm on 2 April 2025, for firms to comply with the ‘naming and marketing’ rules (i.e. ESG 4.3.2R to ESG 4.3.8R of the FCA’s ESG sourcebook ) in relation to a sustainability product which is a UK authorised investment fund in exceptional circumstances where the firm:
- has submitted to the FCA a completed application for approval of amended disclosures in line with ESG 5.3.2R for that fund by 5pm on 1 October 2024; and
- is currently using one or more of the terms ‘sustainable’, ‘sustainability’ or ‘impact’ (or a variation of those terms) in the name of that fund and is intending either to use a label, or to change the name of that fund.”
This is welcome news for funds using sustainability terms in their titles that do not yet align with the new fund name requirements. Sustainability professionals should be cautious though. Sometimes regulatory deadlines get pushed back and give us a little breathing room. Other times, like in California’s GHG emissions disclosure laws, we expect deadlines to get pushed back that stay in place. This can cause a last-minute rush to compliance, and rushed work is more likely to be inaccurate.
Our members can learn more about sustainable finance regulation here.
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