FCA developments – new consultation includes SDR clarifications

For those keeping an eye on SDR… on 10 September 2025 the FCA issued a consultation requesting feedback on a number of areas. 

I have only looked at the SDR / sustainability related text, which (as far as I can tell) does not appear to be controversial.

The proposed amends relate to clarifying that passive / index tracking funds do not need to specifically or individually ‘select’ assets, the clarification indicates that such options will be required to hold assets to ‘meet the fund’s published criteria’.

In addition, there are some proposed changes that should make SDR related reporting more straightforward and flexible. The relevant text begins on page 18 of the document linked below.

https://www.fca.org.uk/publication/consultation/cp25-24.pdf 

Other recent publications include:

• https://www.fca.org.uk/firms/climate-change-sustainable-finance/reporting-requirements
• https://www.fca.org.uk/publications/multi-firm-reviews/climate-reporting-asset-managers-life-insurers-fca-regulated-pension-providers (important)
• https://www.gov.uk/government/consultations/exposure-drafts-uk-sustainability-reporting-standards  
• https://assets.publishing.service.gov.uk/media/685d0945c779b80d9a0e106b/transition-plan-consultation.pdf

All of which, in my view demonstrates that this immense and complex area remains ‘work in progress’ – which I expect to remain the case for some time.