Alongside this, the FCA has issued a guidance consultation on its new anti-greenwashing rule. With these initiatives, the UK hopes to establish its credentials as a leading light on ESG and climate change, and a rival to the EU, already well down the track with its own ambitious proposals, including a consultation on SFDR 2.0.

The UK regime will only apply to UK fund managers for now, although a consultation on overseas retail funds sold into the UK is expected to follow, possibly with other consultations over time to extend the regime’s scope. The changes will come at a not insubstantial cost – in an updated cost analysis, the FCA has said the new regime will involve total one-off costs of c. GBP204.8m and new ongoing annual costs of c.GBP34.2m. Those are significant sums. This paper gives our views on certain FAQs – please get in touch if you also wish to see our full briefing on the new rules or our separate FAQs on the anti-greenwashing consultation.