ESG trends in 2021: momentum, principles, and assurance

From a UK government perspective the tone was arguably set at the end of last year when the government set out its ‘ten point plan for a green industrial revolution’, and Richard Monks, the strategy director at the FCA provided initial insight into the seven regulatory principles that the FCA would use to base its regulation of ESG upon. A key aspect of this was that in assessing holdings, a firm should assure ESG data quality including understanding the source and derivation.

Throughout 2021 the momentum has continued to build. We have seen the FCA adopt climate change as a part of its overall regulatory remit and it gets a great deal of coverage in the FCA’s 2021 business plan, so there is no doubt that, as Richard Monks said, ‘sustainable investing is here to stay’, and that there is a real focus on building trust in this market.
 

Partly that trust comes from disclosure – in 2021 we have seen a consultation on introducing mandatory Taskforce on Climate Related Financial Disclosure (TCFD) reporting for asset managers from 2023. This focuses on things like risk management and governance, but also disclosing on metrics and targets – firms will need to disclose the metrics they use to assess climate-related risks and opportunities. This links back to the FCA’s principle of assuring ESG data quality. In November the FCA issued a discussion paper on sustainability disclosures and fund labelling, and the government’s ‘Greening Finance’ report sets out next steps in terms of, for example, the introduction of a UK Green Taxonomy.

These developments are similar to some of the developments we are seeing in the EU: for example, the Sustainable Finance Disclosures Regulation (SFDR), which sets out in detail how firms should disclose on things like climate-related risk in portfolios, and the Taxonomy Regulation, also known as the EU Green Taxonomy, which also seeks to provide these commonly-agreed terms. SFDR’s Level 1 requirements were implemented in March with a series of requirements on the Taxonomy applying in early 2022.

It is also worth noting that there are now these two different regulatory approaches to ESG between the UK and the EU. The UK has taken a more ‘principles’ and ‘outcomes’ based approach, while the EU has taken a more ‘prescriptive’ approach.

In both instances, however, there is an emphasis on disclosure, on data quality, and on assurance, so that there is transparency and so the end investor can make informed investment decisions and have confidence that the product they have bought does what it says it will do.
 

There are a host of additional ways that funds and firms can seek to demonstrate their ESG credentials. One example is the UK Stewardship Code, which applies to asset managers, asset owners and service providers, and which requires signatories to provide annual reports on policies and outcomes in terms of the economy, the environment and society. The Financial Reporting Council published its first list of approved signatories of the code on 06 September, and a third of applicants were unsuccessful, which shows that the bar was significantly raised with this iteration of the code, with a focus on achieving outcomes - not just on having a policy.