Every FCA-authorised firm
The anti-greenwashing rule, ESG 4.3.1R, for references to the sustainability characteristics of products and services.
Banks, insurers, advisers, platforms and managers alike.FCA · SDR · Requirements
SDR reporting requirements in the UK: the FCA’s rules for financial firms
The SDR reporting requirements UK firms meet are FCA Handbook rules in the ESG sourcebook, and which ones bind a firm depends on what it is.
Every authorised firm meets the anti-greenwashing rule; managers of UK funds meet the naming, labelling and disclosure rules; and managers over £5bn publish an entity report.
SDR is not UK SRS: it governs investment products and the firms that make them, not company annual reports.
In one table
SDR reporting requirements UK firms face, one line each
Each requirement with the Handbook provision it comes from, as the rules stand on 11 October 2026.
The regime overview is on the FCA Sustainability Disclosure Requirements page.
| Requirement | Who | When | Provision |
|---|---|---|---|
| Sustainability references consistent, fair, clear and not misleading | All FCA-authorised firms | From 31 May 2024 | ESG 4.3.1R |
| Use a label only if the criteria are met, and notify the FCA | Managers of UK funds | From 31 Jul 2024 | ESG 4.1.1R, 4.1.7R, 4.2 |
| Restricted terms in names and promotions only with genuine characteristics | Managers, for retail clients | By 2 Dec 2024 | ESG 4.3.2R–4.3.5R |
| Consumer-facing disclosure, two A4 pages at most | Managers using a label or restricted term | With the product | ESG 5.2 |
| Pre-contractual disclosure | Managers using a label or restricted term | With the product | ESG 5.3 |
| Public product-level report (Part B) | Managers using a label or restricted term | Within 16 months, then annually | ESG 5.4.3R(1), 5.5 |
| Sustainability entity report | Managers with £5bn or more | 2 Dec 2025 or 2 Dec 2026, then annually | ESG 5.4.2R, 5.4.3R(2), 5.6 |
| TCFD entity report | Asset managers and asset owners with £5bn or more | Annually | ESG 2.2; ESG 1A.1.2R |
| Climate risks in retail product communications | ESG 2 firms | From 25 Sep 2026 | ESG 2.3.1BR |
| Scope 1, 2 and 3 data to eligible clients on request | ESG 2 firms | From 30 Jun 2027 | ESG 2.3.5AR |
| Show labels and disclosures to retail investors; flag overseas funds | Distributors to retail clients | When distributing | ESG 4.1.16R–4.1.19R |
The other UK regimes, from UK SRS to the Stewardship Code, are collected on the UK sustainability reporting requirements hub.
Who is in scope
Three groups of firms, three sets of rules
ESG 3.1.2R sets the scope in three layers, and the first layer is every authorised firm.
ESG 4.1.1R(1), the ban on using labels without qualifying, and ESG 4.3.1R, the anti-greenwashing rule, apply to all firms.
Distributors of sustainability products to retail clients have their own rules in ESG 4.1.16R to 4.1.19R.
Everything else in ESG 4 and 5 applies to four kinds of manager: UK UCITS management companies, ICVCs without a separate management company, full-scope UK AIFMs and small authorised UK AIFMs.
Life insurers and FCA-regulated pension providers sit in the climate rules in ESG 1A.1.1R, not in SDR’s labelling and naming rules.
Portfolio management is outside ESG 4 and 5 because the FCA did not finalise CP24/8.
An FCA-authorised firm
Managers of UK funds
Naming and marketing, labels if chosen, consumer-facing and pre-contractual disclosures, product reports, and the entity report over £5bn.
UK UCITS management companies and UK AIFMs (ESG 3.1.2R).Distributors and asset owners
Distributors pass on labels and disclosures; life insurers and pension providers report under the separate TCFD rules in ESG 2.
ESG 4.1.16R–4.1.19R; ESG 1A.1.1R.All firms
The anti-greenwashing rule, and what it leaves out
ESG 4.3.1R(2) reads: “A firm must ensure that any reference to the sustainability characteristics of a product or service is: (a) consistent with the sustainability characteristics of the product or service; and (b) fair, clear and not misleading.”
It came into force on 28 November 2023 and has applied since 31 May 2024, under ESG TP 1.8R.
It reaches communications with a client in the UK and financial promotions communicated or approved for a person in the UK, excluding excluded communications and third-party prospectuses.
The FCA’s guidance is FG24/3, which is non-Handbook guidance and does not create new obligations.
FG24/3 ¶2.15 says the rule relates to products and services, so a firm’s claims about itself fall under the Principles, the Consumer Duty and consumer law instead.
The rule in depth, with the FCA’s examples, is on the anti-greenwashing rule page.
Voluntary labels
Four labels, drafted as a prohibition
ESG 4.1.1R(1) says a firm “must not” use the four labels, and (2) then allows a qualifying manager to use one from 31 July 2024.
The general criteria in ESG 4.2.4R require a clear, specific and measurable objective and at least 70% of the product’s gross assets invested in line with it.
Those assets must be selected against a robust, evidence-based standard that is an absolute measure of environmental or social sustainability, and the rest must not conflict with the objective.
The manager must obtain an independent assessment of that standard and have an escalation plan and stewardship strategy, under ESG 4.2.9R.
A label is notified to the FCA under ESG 4.1.7R, not approved, and ESG 4.1.5R(2) forbids claiming FCA approval.
The FCA has published examples of good and poor practice for labels, the latest in February 2026, on its SDR regime page.
| Label | What the assets do | Provision |
|---|---|---|
| Sustainability Focus | Are environmentally or socially sustainable | ESG 4.2.13R |
| Sustainability Improvers | Have the potential to improve over time | ESG 4.2.14R–4.2.15R |
| Sustainability Impact | Achieve a pre-defined, positive, measurable impact | ESG 4.2.16R–4.2.17R |
| Sustainability Mixed Goals | Combine two or more of the above | ESG 4.2.18R–4.2.19R |
Naming and marketing
Thirteen restricted terms, three of them label-only
ESG 4.3.2R applies where a manager uses restricted terms in a retail product’s name or in a financial promotion about its sustainability characteristics.
The list runs from “ESG” and “climate” to “Paris-aligned”, and ends with any other term implying sustainability characteristics, so it is not closed.
An unlabelled product may use the terms if it genuinely has the characteristics, but not “sustainable”, “sustainability” or “impact” in its name, under ESG 4.3.5R.
It must publish the sentence “This product does not have a UK sustainable investment label” with a short explanation of why.
A focus, improvers or mixed goals fund must not use “impact” in its name either, under ESG 4.3.4R(2).
The FCA and the FRC have said the Stewardship Code’s use of “sustainable” does not conflict with these rules, which bite only on the sustainability characteristics of a product, as the Stewardship Code reporting requirements page notes.
What is reported
SDR reporting requirements: disclosures, product and entity reports
ESG 5.1.1R triggers the product disclosures when a manager uses a label or one or more restricted terms, so using the words is enough.
The consumer-facing disclosure in ESG 5.2 must not exceed two pages of A4 and is reviewed annually.
The pre-contractual disclosure in ESG 5.3 sets out the criteria used to decide the product’s sustainability characteristics and any useful metrics.
Part B of the public product-level report must be published within 16 months of first using the label or term, then annually, under ESG 5.4.3R(1).
The sustainability entity report is required “regardless of whether” the manager uses a label or restricted term, under ESG 5.4.2R, unless the £5bn exemption applies.
Its content follows governance, strategy, risk management and metrics and targets, and the FCA points managers to IFRS S1, SASB and GRI in ESG 5.6.
A manager must include its TCFD entity report, or a link to it, in the sustainability entity report.
The FCA’s reporting requirements page confirms the first entity reports were due by 2 December 2025 for the largest managers and by 2 December 2026 for the rest over £5bn.
- 1
Name and marketing
Use restricted terms only with genuine sustainability characteristics; “sustainable”, “sustainability” and “impact” only with a label.
- 2
Label, if chosen
Meet the 70% test and the label’s criteria, notify the FCA, and review at least every 12 months.
- 3
Consumer-facing disclosure
No more than two A4 pages, reviewed annually.
- 4
Pre-contractual disclosure
Criteria for sustainability characteristics, metrics, and the label or the unlabelled statement.
- 5
Product report
Part B within 16 months of first use, then annually.
- 6
Entity report
Annually, if £5bn or more, with the TCFD entity report included or linked.
Asset owners and climate
The TCFD rules beside SDR, after the 2026 streamlining
The FCA’s climate rules for asset managers and asset owners date from PS21/24 and sit in ESG 2, not in SDR.
They apply to asset managers, life insurers and FCA-regulated pension providers with £5bn or more, on a three-year rolling average, under ESG 1A.1.2R.
The annual TCFD entity report survives in ESG 2.2.
The public TCFD product report was removed by FCA 2026/59, in force on 25 September 2026 according to Handbook Notice 144.
In its place, ESG 2.3.1BR asks firms to consider whether climate risks are materially relevant to a product and to include them in retail communications.
ESG 2.3.5AR requires Scope 1, 2 and 3 data for clients who need it for their own disclosures, once per client per product per year, and the FCA says it applies from 30 June 2027.
Occupational pension schemes report under DWP regulations overseen by TPR, on the pension scheme climate reporting requirements page, and the TCFD rule set is on the TCFD reporting requirements page.
When
The SDR reporting requirements, in date order
| Date | What happens | Provision |
|---|---|---|
| 28 Nov 2023 | PS23/16 published; rules made | PS23/16 |
| 31 May 2024 | Anti-greenwashing rule applies to all firms | ESG TP 1.8R |
| 31 Jul 2024 | Labels may be used | ESG 4.1.1R(2) |
| 2 Dec 2024 | Naming and marketing and disclosure rules in force for managers | ESG TP 1.9R |
| 2 Dec 2025 | First entity reports, largest managers | ESG 5.4.3R(2)(a) |
| 30 Jun 2026 | Long-stop for first product reports with a longer period | ESG 5.4.3R(1B) |
| 25 Sep 2026 | TCFD product reports replaced | FCA 2026/59 |
| 2 Dec 2026 | First entity reports, other managers over £5bn | ESG 5.4.3R(2)(b) |
| 30 Jun 2027 | Scope 1, 2 and 3 on request applies | ESG 2.3.5AR |
The FCA’s December 2025 amendments, consulted on in CP25/24 and made by Handbook Notice 136, introduced the flexible product-report periods in ESG 5.4.3R(1A) and (1B).
Enforcement
Rules, not guidance
The labelling, naming and disclosure provisions are Handbook rules marked R, so a breach is a breach of FCA rules.
The FCA may impose a financial penalty on an authorised person that has contravened a requirement under section 206 of FSMA 2000.
Using a label without meeting ESG 4.2 breaches the prohibition in ESG 4.1.1R(1), rather than merely failing to earn a label.
FG24/3 is guidance under section 139A, and the 70% figure for unlabelled funds in ESG 4.3.6G is an example in guidance, not a rule.
Not in the rules
What SDR does not require
It does not require any firm to use a label.
It does not require third-party assurance of product or entity reports, though a label needs an independent assessment of the manager’s standard.
It does not apply its labelling and naming rules to portfolio managers, pension products or overseas funds, though distributors must flag overseas funds as outside the regime.
It does not catch a firm’s claims about itself under the anti-greenwashing rule.
It does not require listed companies to do anything: their regime is UK SRS under PS26/19.
Requirements still quoted that no longer apply
A TCFD product report with five metrics — replaced on 25 September 2026.
SDR for portfolio managers from December 2024 — proposed in CP24/8 and not finalised.
“FCA-approved” labels — labels are notified, and the claim is prohibited.
A £50bn enhanced SM&CR threshold for the first entity reports — the SYSC test now reads £65bn.
The other regimes
SDR and UK SRS: two regimes, two audiences
SDR is about investment products and the firms that make and sell them, and it sits in the FCA’s conduct rules.
UK SRS S1 and S2 are corporate reporting standards, published by the Department for Business and Trade on 25 February 2026 as voluntary standards.
The FCA’s PS26/19 puts listed companies in UKLR 6, 14, 15, 16 and 22 on a comply-or-explain basis across UK SRS, for accounting periods beginning on or after 1 January 2027.
The two meet in the data: a manager’s entity report and Scope 3 figures depend on what investee companies publish under UK SRS, set out on the UK SRS reporting requirements page.
A listed asset manager can therefore face both: UK SRS as an issuer and SDR as a manager, which the UK SRS and the FCA page separates.
A UK asset manager’s group may also meet EU entity-level rules where an EU subsidiary passes the thresholds on the CSRD reporting requirements page.
What is changing
Open items, labelled as such
The FCA says it continues to consider its approach to entity-level TCFD reporting, following its review of the TCFD rules.
The extension of SDR to portfolio management remains unfinalised, with no date given.
The institutional-client data rule in ESG 2.3.5AR applies from 30 June 2027.
None of these is a rule change until the FCA makes an instrument.
Check yourself
Six statements on SDR
Each answer names the Handbook provision it turns on.
The policy reasons are in PS23/16, and the rules as they stand are in the ESG sourcebook.
The wider ESG picture is on the ESG reporting requirements page.
True or false?
The anti-greenwashing rule applies only to firms that use a sustainability label.
A labelled Sustainability Focus fund may use “impact” in its name.
A manager below £5bn under management must still produce an SDR entity report.
The 70% asset threshold for unlabelled funds is a rule.
A manager may tell clients the FCA has approved its label.
SDR’s labelling rules have been extended to portfolio management.
0 of 6 answered.
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Frequently asked
SDR reporting requirements UK, answered
What is SDR in the UK?
SDR is the FCA’s Sustainability Disclosure Requirements and investment labels regime for financial firms, made in PS23/16 on 28 November 2023 and set out in the ESG sourcebook.
It covers the anti-greenwashing rule, four voluntary investment labels, naming and marketing rules, consumer-facing and pre-contractual disclosures, and product- and entity-level sustainability reports.
Is SDR the same as UK SRS?
No. SDR is an FCA conduct and disclosure regime for asset managers and other financial firms.
UK SRS S1 and S2 are corporate reporting standards published by the Department for Business and Trade on 25 February 2026 as voluntary standards; the FCA’s PS26/19 puts listed companies in UKLR 6, 14, 15, 16 and 22 on a comply-or-explain basis against UK SRS for accounting periods from 1 January 2027.
Who does the anti-greenwashing rule apply to?
All FCA-authorised firms, from 31 May 2024.
ESG 4.3.1R requires any reference to the sustainability characteristics of a product or service to be consistent with those characteristics and fair, clear and not misleading, where the firm communicates with a client in the UK or communicates or approves a financial promotion to a person in the UK.
Does the anti-greenwashing rule cover claims a firm makes about itself?
No. The FCA’s guidance FG24/3 says the rule relates to products and services; claims a firm makes about itself are governed by the FCA Principles, the Consumer Duty where relevant, and consumer-law guidance from the CMA and ASA.
Are SDR labels mandatory?
No firm has to use a label.
ESG 4.1.1R is drafted as a prohibition: no firm may use the four labels except a qualifying manager that meets the criteria in ESG 4.2 and notifies the FCA.
Using a label without qualifying breaches that prohibition.
What are the four SDR labels?
Sustainability Focus, Sustainability Improvers, Sustainability Impact and Sustainability Mixed Goals.
Each needs a clear, specific and measurable sustainability objective, at least 70% of the product’s gross assets invested in line with it, and selection against a robust, evidence-based standard that is an absolute measure of sustainability.
Can an unlabelled fund call itself sustainable?
Not in its name.
ESG 4.3.5R lets an unlabelled product use most restricted terms if it has genuine sustainability characteristics, but not “sustainable”, “sustainability” or “impact” or variations of them in its name.
It must also publish the statement “This product does not have a UK sustainable investment label” and the disclosures.
Which terms do the SDR naming and marketing rules restrict?
Thirteen, in ESG 4.3.2R(2): ESG; environment or environmental; social; climate; sustainable or sustainability; green; transition; net zero; impact; responsible; sustainable development goals or SDGs; Paris-aligned; and any other term implying sustainability characteristics.
The last is open-ended.
Who has to produce an SDR entity report?
A manager of UK UCITS or AIFs with £5bn or more under management in its sustainability in-scope business, on a three-year rolling average, whether or not it uses labels or restricted terms.
The largest managers published by 2 December 2025; the rest over £5bn must publish by 2 December 2026, then annually.
Do asset owners have SDR reporting requirements?
Not under ESG 4 and 5, which apply to managers.
Life insurers and FCA-regulated pension providers with £5bn or more report under the separate TCFD rules in ESG 2: an annual TCFD entity report, climate risks in retail communications for products, and Scope 1, 2 and 3 data on request.
Occupational pension schemes are regulated by TPR, not the FCA.
When is the first SDR product report due?
Within 16 months of the manager first using a label or a restricted term for the product, then annually.
Managers that started before 28 February 2025 could choose a longer first period if they published by 30 June 2026.
What must a consumer-facing disclosure contain?
The product’s sustainability goal, its approach, relevant metrics and, if labelled, the label and its descriptor, in no more than two pages of A4. It is reviewed at least annually and kept for five years.
Does SDR apply to portfolio managers?
The labelling, naming and disclosure rules do not.
The FCA consulted on an extension in CP24/8 but decided it was not the right time to finalise those rules.
The anti-greenwashing rule does apply to portfolio managers, as it applies to all authorised firms.
Does SDR apply to overseas funds?
Overseas funds are not in the UK labelling regime.
Distributors of recognised overseas schemes that use restricted terms must display the notice “This product is based overseas and is not subject to UK sustainable investment labelling and disclosure requirements”, under ESG 4.1.19R.
What happened to TCFD product reports?
FCA 2026/59, in force on 25 September 2026, removed the public TCFD product report.
Firms must now consider whether climate risks are materially relevant to a product and include them in retail communications, and supply Scope 1, 2 and 3 data to eligible clients on request, a duty that applies from 30 June 2027.
The TCFD entity report remains.
What happens if a firm breaches SDR rules?
SDR rules are FCA Handbook rules, so a breach can lead to FCA enforcement, including a financial penalty under section 206 of the Financial Services and Markets Act 2000.
Claiming that the FCA approved a label is itself a breach of ESG 4.1.5R.
Is SDR assurance required?
No SDR rule requires third-party assurance of product or entity reports.
The criteria for a label do require the manager to obtain an independent assessment of the standard it uses to select assets, under ESG 4.2.9R.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 21 sources fromFinancial Conduct Authoritylegislation.gov.ukDepartment for Business and Trade
- Financial Conduct AuthorityFCA Handbook, ESG 3.1 — application of ESG 4 and ESG 5
Who each rule binds: all firms, distributors, managers; the £5bn entity-report exemption (ESG 3.1.3R).
- Financial Conduct AuthorityFCA Handbook, ESG 4.1 — sustainability labels
The four labels as a prohibition with a carve-out; notification; no claim of FCA approval.
- Financial Conduct AuthorityFCA Handbook, ESG 4.2 — general and specific label criteria
The 70% asset test, the robust evidence-based standard and the label-specific tests.
- Financial Conduct AuthorityFCA Handbook, ESG 4.3 — naming and marketing, anti-greenwashing
ESG 4.3.1R (all firms) and the thirteen restricted terms in ESG 4.3.2R.
- Financial Conduct AuthorityFCA Handbook, ESG 5 — disclosures
Consumer-facing (ESG 5.2), pre-contractual (ESG 5.3), product and entity reports (ESG 5.4–5.6).
- Financial Conduct AuthorityFCA Handbook, ESG 5.4 — preparation of sustainability reports
The 16-month product-report clock, the 30 June 2026 long-stop and the entity-report deadlines.
- Financial Conduct AuthorityFCA Handbook, ESG 1A.1 — application of ESG 2 (TCFD)
Asset managers and asset owners in the TCFD regime, and its £5bn exemption.
- Financial Conduct AuthorityFCA Handbook, ESG 2.2 — TCFD entity report
The entity report that survives the 2026 streamlining.
- Financial Conduct AuthorityFCA Handbook, ESG 2.3 — product-level climate information
ESG 2.3.1BR (retail communications) and ESG 2.3.5AR (Scope 1, 2 and 3 on request).
- Financial Conduct AuthoritySustainability Disclosure Requirements (SDR) regime
The FCA’s summary for managers and distributors, updated 8 June 2026.
- Financial Conduct AuthoritySustainability reporting requirements
Updated 30 September 2026: entity reports by 2 December 2025 and 2026; institutional-client rule from 30 June 2027.
- Financial Conduct AuthorityClimate change and sustainable finance
The FCA hub across listed companies, asset managers and asset owners.
- Financial Conduct AuthorityPS23/16: Sustainability Disclosure Requirements (SDR) and investment labels
The policy statement of 28 November 2023 and the reasons for each rule.
- Financial Conduct AuthorityPS23/16 (PDF), Annex 2: overview of the regime
Chapters on labels, naming, disclosures, distributors and scope.
- Financial Conduct AuthorityFG24/3: Finalised non-handbook guidance on the anti-greenwashing rule
Guidance, not rules; firm-level claims sit outside ESG 4.3.1R (¶2.15).
- Financial Conduct AuthorityCP24/8: Extending the SDR regime to portfolio management
The FCA decided it is not the right time to finalise these rules.
- Financial Conduct AuthorityHandbook Notice 144 (September 2026)
FCA 2026/59, in force 25 September 2026, replacing TCFD product reports.
- Financial Conduct AuthorityPS21/24: climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers
The 2021 TCFD rules for asset managers and asset owners.
- legislation.gov.ukFinancial Services and Markets Act 2000, section 206
The FCA’s power to fine an authorised person for a breach of its rules.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The separate listed-company regime against UK SRS.
- Department for Business and TradeUK Sustainability Reporting Standards: UK SRS S1 and UK SRS S2
Voluntary corporate standards published 25 February 2026, not part of SDR.
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