On July 30, 2024, the Regulator published its market oversight report on  how trustees are complying with their environmental, social and governance (ESG) duties, including in respect of climate change.

The Regulator finds that the vast majority of trustees are meeting their ESG-related disclosure requirements, but deeper analysis found that many are only delivering minimum compliance.

Some of the suggestions the Regulator makes are that trustees could:

  • Include appropriate levels of detail in their reporting to demonstrate that they are effectively managing financially material ESG related risks.
  • Consider going beyond climate change reporting and voluntarily becoming early adopters of reporting on aspects such as social factors or nature related reporting.
  • Take a more thorough approach to assessing their scheme’s arrangements with asset managers in order to protect saver outcomes.


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