SDR · the FCA’s rules

FCA sustainability disclosure requirements: four sets of rules, read at the Handbook

The FCA’s sustainability disclosure requirements, known as SDR, were made in PS23/16 on 28 November 2023 and live in the ESG sourcebook.

They combine an anti-greenwashing rule for every authorised firm with labels, naming rules and disclosures for fund managers.

This page takes each one at its provision, with the dates as the Handbook stamps them.

Check a fund name SDR dates to 2026

The regime

What FCA SDR is, and who it reaches

SDR is the FCA’s regime for how investment products are described to the people who buy them.

HM Treasury’s Implementation Update 2024 describes the package as investment labels, naming and marketing rules, an anti-greenwashing rule for all FCA-authorised firms, and disclosure rules.

Only one part reaches every firm: the anti-greenwashing rule, which applies to banks, insurers, advisers and platforms as much as to fund managers.

The rest is written for managers of UK funds: UK UCITS management companies, investment companies with variable capital, and full-scope and small authorised UK alternative investment fund managers.

It sits alongside, not inside, the FCA’s older TCFD rules for asset managers and its new UK SRS rules for listed companies.

The government’s wider package, of which the FCA’s rules are one part, is on UK sustainability disclosure requirements.

FCA Handbook ESG 3.1.2R, 3.1.3R, 4 and 5.
Part	Who it binds	Where
Anti-greenwashing	Every FCA-authorised firm	ESG 4.3.1R
Labels	UK UCITS management companies, ICVCs, full-scope and small authorised UK AIFMs — and a prohibition on everyone else	ESG 4.1, 4.2
Naming and marketing	Those managers, for retail products	ESG 4.3.2R–4.3.8R
Disclosures	Those managers; entity report above £5bn	ESG 5

FCA SDR dates

SDR from 2023 to 2026, date by date

The regime was phased in, and several dates have moved since it was made. These are the dates in the rules, with what changed them.

28 November 2023
PS23/16 made
The anti-greenwashing rule comes into force on this date, but does not yet apply.
23 April 2024
FG24/3 finalised
Guidance on the anti-greenwashing rule, consulted on as GC23/3.
31 May 2024
Anti-greenwashing rule applies
ESG TP 1.8R: the rule applies from this date to all authorised firms.
31 July 2024
Labels available
ESG 4.1.1R(2): a qualifying manager may use a label from this date.
2 December 2024
Naming and marketing longstop
ESG TP 1.9R: the rules apply from first label use, or this date at the latest.
2 April 2025
Temporary flexibility ends
For firms with a pending application using “sustainable”, “sustainability” or “impact” in a fund name, until 5pm.
2 December 2025
Entity reports: largest managers
ESG 5.4.3R(2)(a): managers meeting the enhanced SM&CR test.
19 December 2025
Minor amendments
Handbook Notice 136: the first product report moves to within 16 months of first using a label or term.
February 2026
Good and poor practice
The FCA publishes further examples for labels.
30 June 2026
First product report long-stop
For managers who started using a label or term before 28 February 2025.
10 July 2026
The enhanced-firm test moves
SYSC 23 Annex 1 8.2R, which ESG 5.4.3R(2) relies on, rises from £50bn to £65bn.
25 September 2026
A third permitted use of the terms
ESG 4.3.2R(3)(c), added by FCA 2026/59, for climate-risk disclosures under ESG 2.3.1BR.
2 December 2026
Entity reports: other managers ≥ £5bn
ESG 5.4.3R(2)(b), on a three-year rolling average.

The dates are read at the ESG sourcebook and ESG 5; the February 2026 examples are listed on the FCA’s SDR regime page.

A note written in 2024 will say 12 months for the first product report and £50bn for the enhanced-firm test; both have since changed.

The wider UK sequence is on the UK sustainability regulation timeline.

ESG 4.3.1R

The anti-greenwashing rule, and what it does not cover

The anti-greenwashing rule is ESG 4.3.1R, and it applies to a firm whether or not it is undertaking sustainability in-scope business.

It reaches a firm that communicates with a client in the United Kingdom about a product or service, or that communicates or approves a financial promotion to a person in the United Kingdom.

It came into force on 28 November 2023 and applies from 31 May 2024.

It has four limits, and each is routinely missed.

It carves out excluded communications and third-party prospectuses on its face.

It covers products and services, not claims a firm makes about itself: the FCA’s guidance, FG24/3, says the Principles, the Consumer Duty and the CMA and ASA guidance apply to firm-level claims instead.

It needs a UK client or a UK recipient, and it binds FCA-authorised firms only.

FG24/3 was consulted on as GC23/3 and is guidance, not a rule; one FCA page cites it as FG24/2, which is unrelated mortgage guidance.

The rule, verbatim

“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.”

ESG 4.3.1R(2).

ESG 4.1 and 4.2

The four labels: a prohibition with a carve-out

ESG 4.1.1R(1) says a firm “must not” use the four labels.

ESG 4.1.1R(2) then lets a qualifying manager use one from 31 July 2024. So a label used without qualifying breaches a prohibition.

FCA Handbook ESG 4.1.1R and ESG 4.2. General criteria for all four at ESG 4.2.4R.
Label	The product’s assets…	Specific rules
Sustainability focus	…are environmentally and/or socially sustainable, judged against a robust, evidence-based standard that is an absolute measure	ESG 4.2.13R
Sustainability improvers	…have the potential to improve over time, with a timescale and short- and medium-term targets	ESG 4.2.14R–4.2.15R
Sustainability impact	…aim for a pre-defined, positive, measurable impact, with a theory of change	ESG 4.2.16R–4.2.17R
Sustainability mixed goals	…pursue two or more of the above	ESG 4.2.18R–4.2.19R

Every label shares the general criteria of ESG 4.2.4R.

The product needs an explicit sustainability objective that is clear, specific and measurable.

At least 70% of the gross value of its assets must be invested in accordance with that objective, selected against a robust, evidence-based standard that is an absolute measure of environmental or social sustainability.

Assets outside the 70% must not have attributes that conflict with the objective, and the manager needs robust, evidence-based key performance indicators.

At manager level, the standard must be assessed independently of the investment process, and the label reviewed at least every 12 months.

A manager notifies the FCA through its online system under ESG 4.1.7R; there is no approval, and ESG 4.1.5R(2) forbids claiming that the FCA has conferred or approved a label.

The FCA published further examples of good and poor practice for labels in February 2026.

ESG 4.3.2R–4.3.8R

Naming and marketing: thirteen terms, three reserved

The naming and marketing rules apply where a manager, dealing with retail clients, uses a restricted term in a product’s name or in a financial promotion about its sustainability characteristics.

ESG 4.3.2R(2) lists the terms, from “ESG” to “Paris-aligned”, and ends with “any other term which implies that a sustainability product has sustainability characteristics”, so the list is not closed.

Only three are reserved to labelled products: “sustainable”, “sustainability” and “impact”.

An unlabelled product may use the other ten if its name accurately reflects genuine sustainability characteristics, it produces the consumer-facing, pre-contractual and Part B disclosures, and it publishes the statement “This product does not have a UK sustainable investment label”.

For unlabelled products the 70% figure appears only as guidance, in ESG 4.3.6G, and as an example; for labelled products it is a rule.

On 25 September 2026 a third permitted use was added at ESG 4.3.2R(3)(c): a manager may use the terms to meet the new duty to include climate-related risks in retail communications.

ESG 4.3.2R(2), 4.3.4R(2), 4.3.5R.
Term	Unlabelled fund may use it in its name?
“Sustainable”, “sustainability”	No
“Impact”	No — and not in a focus, improvers or mixed goals name either
“ESG”, “environmental”, “social”, “climate”, “green”, “transition”, “net zero”, “responsible”, “SDG”, “Paris-aligned”	Yes, on the ESG 4.3.5R conditions
Any other term implying sustainability characteristics	Caught by limb (m) — judge case by case

Check a product

Label, name and disclosures: what applies to your fund

The checker asks what kind of firm you are, whether the product is sold to retail clients, which label it uses and which term is in its name.

Each answer comes back with the provision that decides it.

It will tell a portfolio manager that the naming rules do not reach it, and that the anti-greenwashing rule does.

It will tell a manager with an improvers label that “impact” cannot appear in the fund’s name.

And it will tell an unlabelled fund called “Global Sustainable Equity” that the name needs to change.

It stores nothing and sends nothing: it reads the rules you would otherwise read yourself.

SDR check · your firm, your product

Your firmLabel you use or planTerm in the product’s nameOffered to retail clientsAssets under management (three-year rolling average)

AppliesAnti-greenwashing ruleAny reference to a product’s or service’s sustainability characteristics must be consistent with them and fair, clear and not misleading, when communicating with a UK client or a UK promotion. It does not reach claims a firm makes about itself.ESG 4.3.1R; ESG 3.1.2R(1); applies from 31 May 2024 (ESG TP 1.8R)
Prohibited“Sustainable” in the name needs a labelAn unlabelled product must not use “sustainable”, “sustainability” or “impact”, or any variation of them, in its name.ESG 4.3.5R(1)(b)
RuleProduct disclosuresA consumer-facing disclosure of no more than two A4 pages, pre-contractual disclosures, and a public product-level report, first published within 16 months. Using the words is enough to trigger them.ESG 5.1.1R; ESG 5.2.6R; ESG 5.4.3R(1)
RuleEntity-level report — first due by 2 December 2026Required whether or not you use a label or a restricted term, across the four pillars. The enhanced-SMCR test that sets the earlier date is now £65bn, raised from £50bn on 10 July 2026.ESG 5.4.2R; ESG 5.4.3R(2); ESG 5.6.1R(1); SYSC 23 Annex 1 8.2R

Indicative, not advice.

The thirteenth restricted term is open-ended: any term implying sustainability characteristics.

Read ESG 4 and ESG 5 at the FCA Handbook before relying on an answer.

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ESG 5

SDR disclosures: four documents, one that does not depend on labels

FCA Handbook ESG 5, read at the live Handbook; ESG 3.1.3R exemption below £5bn on a three-year rolling average.
Disclosure	Triggered by	Timing and form	Provision
Consumer-facing	A label or any restricted term	No more than two pages of A4; reviewed annually	ESG 5.1.1R, 5.2.6R
Pre-contractual	A label or any restricted term	Alongside the consumer-facing disclosure	ESG 5.1.1R
Product-level report	A label or any restricted term	First report within 16 months of first use	ESG 5.4.3R(1), 5.5.6R
Entity-level report	Nothing — required regardless of labels, above £5bn	By 2 Dec 2025 (enhanced firms) or 2 Dec 2026	ESG 5.4.2R, 5.4.3R(2), 3.1.3R

Using a restricted term is enough to trigger the product disclosures under ESG 5.1.1R; a label is not needed.

The entity-level report is the one obligation that does not turn on labelling: ESG 5.4.2R requires it regardless of whether a manager uses a label or any of the terms.

Its content follows the four pillars of governance, strategy, risk management, and metrics and targets.

The earlier deadline depends on the enhanced SM&CR test in SYSC 23 Annex 1, which rose from £50 billion to £65 billion of assets under management on 10 July 2026.

How the four pillars work is on the four pillars of sustainability reporting, and the separate TCFD entity report for asset managers on TCFD reporting requirements.

Not finalised

Portfolio managers and SDR: one rule applies, the rest do not

The FCA consulted in CP24/8, from 23 April to 14 June 2024, on extending SDR to portfolio management.

In February 2025 it said it would no longer publish a policy statement in the second quarter of 2025, and later that it was not the right time to finalise rules.

So labels, naming rules and the ESG 5 disclosures do not apply to portfolio management.

The anti-greenwashing rule does, because it binds all firms.

The government has also said it would consult on bringing overseas funds recognised under the Overseas Funds Regime into SDR, according to its Implementation Update 2024.

FCA UK SRS and transition plans

The FCA’s other disclosure rules, which are not SDR

People searching for “FCA UK SRS” often land on SDR, and the two are different regimes.

On 30 September 2026 the FCA published PS26/19: listed companies report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

Those rules also ask a listed company to say whether it has published a climate transition plan and where, or why not; nothing in SDR asks for a plan.

The Transition Plan Taskforce’s Disclosure Framework is voluntary guidance, archived by the IFRS Foundation now that the Taskforce no longer exists, and the government’s position on plans is on UK transition plans regulation.

The FCA also changed its TCFD rules for asset managers on 25 September 2026, removing the product-level report under FCA 2026/59.

All of it is mapped on the UK sustainability regulation landscape.

Three FCA regimes, three audiences

SDR: how funds are labelled, named and described.

ESG 2: TCFD entity reports by asset managers and asset owners.

UK SRS listing rules: listed companies, from 2027.

Frequently asked

FCA SDR: questions people ask

What are the FCA sustainability disclosure requirements?

The FCA’s Sustainability Disclosure Requirements, made in PS23/16 on 28 November 2023, are four linked sets of rules in the ESG sourcebook: an anti-greenwashing rule for every authorised firm, four optional sustainability labels for funds, naming and marketing rules that restrict thirteen sustainability terms, and disclosure rules for managers.

When did SDR come into force?

In stages.

The anti-greenwashing rule applies from 31 May 2024; managers could use labels from 31 July 2024; the naming and marketing rules applied from the first use of a label or 2 December 2024 at the latest; and entity-level reports are due by 2 December 2025 for the largest managers and 2 December 2026 for others with £5bn or more.

What are the four SDR labels?

Sustainability focus, Sustainability improvers, Sustainability impact and Sustainability mixed goals.

ESG 4.1.1R prohibits every firm from using them, then allows a qualifying manager to use one for a product that meets the ESG 4.2 criteria, including having at least 70% of its gross assets invested in line with its sustainability objective.

Is an SDR label approved by the FCA?

No. A manager notifies the FCA that it is using a label; there is no approval step, and ESG 4.1.5R(2) forbids a manager from claiming, expressly or by implication, that the FCA has conferred or approved the label.

What is the FCA anti-greenwashing rule?

ESG 4.3.1R: a firm must ensure that any reference to the sustainability characteristics of a product or service is consistent with those characteristics and fair, clear and not misleading.

It applies to all FCA-authorised firms communicating with UK clients or financial promotions to UK persons, from 31 May 2024.

Can a fund without a label call itself sustainable?

Not in its name.

An unlabelled fund may use ten of the thirteen restricted terms, such as “ESG”, “climate” or “transition”, if it meets the ESG 4.3.5R conditions, but not “sustainable”, “sustainability” or “impact”.

It must also say that the product does not have a UK sustainable investment label.

Does SDR apply to portfolio managers?

The labelling, naming and disclosure rules do not: the FCA consulted in CP24/8 on extending them to portfolio management and decided not to finalise rules.

The anti-greenwashing rule does apply, because it binds every authorised firm.

Does SDR require a transition plan?

No. None of the SDR rules requires a firm to have or publish a transition plan.

The Transition Plan Taskforce’s framework is voluntary guidance, now archived by the IFRS Foundation.

Listed companies will state whether they have published a transition plan under the FCA’s separate UK SRS rules from 2027.

Is SDR the same as UK SRS?

No. SDR in the FCA’s sense is its regime for investment products and the firms that make and sell them.

UK SRS is a pair of corporate reporting standards, which the FCA’s listing rules require listed companies to report against, or explain, from 2027.

Both sit inside the government’s wider Sustainability Disclosure Requirements package.

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 15 sources fromFinancial Conduct AuthorityHM TreasuryIFRS Foundation (archived TPT material)

Financial Conduct Authority
PS23/16 — Sustainability Disclosure Requirements (SDR) and investment labels
The policy statement that made the regime, 28 November 2023.
Financial Conduct Authority
PS23/16 (PDF)
The rules as made.
Financial Conduct Authority
FCA Handbook, ESG 4.1 — sustainability labels (read at ?date=2026-08-20)
ESG 4.1.1R’s prohibition and carve-out; notification; no claim of FCA approval.
Financial Conduct Authority
FCA Handbook, ESG 4.3 — naming and marketing (as at 20 August 2026)
The anti-greenwashing rule, the thirteen terms and the unlabelled route.
Financial Conduct Authority
FCA Handbook, ESG 4.3 (as at 30 September 2026)
The third permitted use of the terms added on 25 September 2026.
Financial Conduct Authority
FCA Handbook, ESG 4 — labels, criteria and naming
The chapter, including the ESG 4.2 criteria and the 70% test.
Financial Conduct Authority
FCA Handbook, ESG 5 — disclosures
Consumer-facing, pre-contractual, product-level and entity-level disclosures.
Financial Conduct Authority
FG24/3 — finalised guidance on the anti-greenwashing rule
Non-Handbook guidance, finalised 23 April 2024; firm-level claims outside the rule.
Financial Conduct Authority
GC23/3 — guidance consultation on the anti-greenwashing rule
The consultation, 28 November 2023 to 26 January 2024.
Financial Conduct Authority
Sustainability Disclosure Requirements (SDR) regime
Good and poor practice examples for labels, February 2026; Handbook Notice 136.
Financial Conduct Authority
CP24/8 — extending SDR to portfolio management
Consulted on in 2024; the FCA decided not to finalise rules.
Financial Conduct Authority
Handbook Notice 144 — FCA 2026/59
The consequential change to ESG 4.3.2R, in force 25 September 2026.
Financial Conduct Authority
PS26/19 — UK SRS for listed companies
The FCA’s other disclosure regime, for issuers rather than funds.
HM Treasury
Sustainability Disclosure Requirements: Implementation Update 2024
Where the FCA’s rules sit in the government’s SDR package.
IFRS Foundation (archived TPT material)
TPT Disclosure Framework, October 2023
Voluntary transition-plan guidance; the Taskforce no longer exists.