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ClientEarth response to FCA consultation on climate-related disclosures for asset managers, life insurers and pension providers (CP21/17)
The UK’s Financial Conduct Authority (FCA) has consulted on proposals to clarify and enhance climate-related disclosure requirements for asset managers, life insurers and FCA-regulated pension providers (consultation CP21/17). The FCA has consulted separately on enhancing climate-related disclosures for standard listed issuers (see our response here).
The FCA’s proposals would require firms which manage at least £5 billion in assets to disclose information in line with the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD) at an entity level, as well as ‘product-level’ disclosures on the climate risks of individual investment products. Notably, this would include a requirement for firms to publish transition plans, in line with the TCFD’s recent consultation (see also our response).
ClientEarth welcomes the proposed extension of climate-related disclosures to asset managers, life insurers and pension providers, and supports the introduction of product-level disclosures. However, the proposals do not go far enough. In our response, we propose a number of enhancements to the FCA’s proposals in order to ensure that consumers, investors and other stakeholders receive the granular detail they need and are entitled to expect to make informed decisions, including: