The UK’s newly implemented sustainability disclosure requirements (SDR) have placed additional data management burdens on financial institutions that operate in the UK.
The country’s first such framework, created by the Financial Conduct Authority (FCA), is aimed at preventing greenwashing and fostering trust in British sustainability markets. It’s designed to protect the interests of investors by enshrining strict rules on how financial products can be advertising, marketed and labelled, and seeks to ensure such information is “fair, clear, and not misleading”.
Critics, however, have pointed to several potential pitfalls that face institutions as they put processes in place to comply with the new SDR. Because the FCA requires that all claims must be backed by robust and credible data, many of the new challenges are likely to be borne by firms’ data teams.
New Classifications
Under the SDR, asset managers – and later portfolio managers – will be expected to provide greater transparency into the sustainability claims attached to their funds and provide data to demonstrate the ESG performance of the funds’ component companies.
Institutions and companies in scope will be asked to voluntarily categorise their investment products according to the concentration of sustainability-linked assets within them. There are four categories of declining levels of sustainability, ranging from “Sustainability Focus” to “Sustainability Mixed Goals”.
This reflects but differs from the European Union’s Sustainable Finance Disclosure Regulation (SFDR), in which asset managers are compelled to classify their products’ according to a similar range of categories.
Among several other SDR requirements, asset managers will be asked to provide entity- and product-level disclosures and adhere to new fund naming regulations – which forbid the use of descriptions that it terms as “vague”, including “ESG” and “sustainability”.
Effective Strategy
While the SDR has been welcomed as a good first step by campaigners for stronger and more transparent sustainability markets in the UK, its implementation could prove tricky. Among the challenges institutions face is the code’s apparent incompatibility with other similar regulations that firms would face overseas. Some observers have complained that the SDR’s fund sustainability categories don’t easily match the Articles 6, 8 and 9 classifications of the SFDR.
This is where data managers will be of critical importance.
“As with all regulations, financial institutions must ensure they have an effective data management strategy in place from now, enabling systems to efficiently collect and aggregate ESG risk-related data to evidence sustainability claims both internally and externally,” GoldenSource head of ESG, connections and regulatory affairs Volker Lainer told Data Management Insight.
“Now, much higher levels of scrutiny are needed on the underlying methodologies and calculations involved in determining ESG scores. Firms that prioritise this will find themselves in a much stronger position as and when the next stages of the UK’s SDR are implemented.”
Data Doubts
The FCA announced the details of the SDR in November last year. It stressed at the time the importance of data management to compliance with the SDR last year. Firms in scope should “have in place appropriate resources, governance, and organisational arrangements, commensurate with the delivery of the sustainability objective”, it said.
“This includes ensuring there is adequate knowledge and understanding of the product’s assets and that there is a high standard of diligence in the selection of any data or other information used (including when third-party ESG data or ratings providers are used) to inform investment decisions for the product,” it said.
Legal experts questioned whether the UK’s financial industry would be able to fully comply. In a report published in April, international law firm Baker McKenzie asked whether firms would be able to keep up with the data requirements expected of the regulation, and questioned whether the data would even be available.
Careful Consideration
While gaps in ESG data still exist, A-Team Group’s ESG Data and Tech Summit London heard that the data record is improving with many more vendors providing ever granular datasets. Market figures caution, however, that the data imperative of the SDR should still be carefully considered.
“With more specific product labelling rules set to apply to from July, UK firms must brace themselves for these ongoing changes to better navigate the complexity jungle. It is clear data and regulatory content mapping is the key differentiator for service providers here – relying on trusted vendors that can provide quality, accurate data and content in pre-established delivery formats,” said Martina Macpherson, head of ESG product strategy and management in the Financial Information division at SIX.
“This is the only way firms can back up their sustainability credentials, meaning they will be better placed to meet new regulatory requirements and prepare for those to come later this year.”
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