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United Kingdom

UK FCA Sustainability Disclosure Requirements (SDR) and Investment Labelling: Scope, Anti‑Greenwashing, Entity/Product Disclosures, Retail Naming/Marketing, Distributor Duties and Implementation Timetable

Practice notes
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This one minute guide offers a concise overview of the essential features of the UK Sustainability Disclosure Requirements (SDR) and Labelling regime. Following its October 2022 consultation (CP 22/20), the Financial Conduct Authority (FCA) released its response and the final SDR rules in Policy Statement (PS 23/16) on 28 November 2023. In April 2024, the FCA also issued final guidance on the new anti‑greenwashing rule (FG 24/3). For background, see News: FCA confirms new sustainability disclosure and labelling regime, LNB News 28/11/2023 67, and News Analysis: FCA sets sustainability disclosure rules for investments. For general information on sustainable finance and environmental, social and governance (ESG) matters relevant to the financial services sector, see: Sustainable finance and ESG—overview. For details of the FCA’s priority areas on sustainable finance and ESG, see Practice Note: Sustainable finance and ESG in the UK financial sector—FCA’s priority areas.

What is SDR?

The UK’s SDR sets out requirements covering:

  • a new anti‑greenwashing rule
  • a voluntary labelling regime for products with a sustainability objective within their investment objective
  • product disclosure requirements
  • sustainability entity reporting
  • retail investor‑specific requirements on naming and marketing, consumer‑facing product‑level disclosures and for...
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Chris Ormond
Chris Ormond

Chris Ormond is Knowledge & Innovation Counsel in Goodwin’s Private Investment Funds practice. She joined the firm in October 2022 and works closely with the Private Investment Funds team to provide legal, regulatory and practical insight that supports the delivery of high‑quality, consistent advice to clients.Chris partners with lawyers across the practice to share best practices, develop and curate technical know‑how, and facilitate a joined‑up approach to knowledge management across the funds platform. Her role focuses on enhancing efficiency, consistency and commercial insight across fund structuring, formation and ongoing operational matters. She is also actively involved in the development and deployment of legal technology and generative AI solutions within the funds practice, helping lawyers use these tools in a practical, risk‑aware way to enhance drafting, analysis and knowledge sharing.She has particular expertise in real estate funds and related regulatory issues....

Andrew Henderson
Dr Andrew Henderson

Andrew Henderson, based in London, is a partner in Goodwin’s Financial Industry, FinTech, and Private Investment Funds practices. He has over twenty years of experience giving counsel and advice on UK and EU financial services and markets law and regulation, working closely with colleagues in Goodwin’s EU offices.Dr. Henderson’s work includes advice on the application of regulation, the management of regulatory risk, governance and the relationships with regulatory authorities. This includes advice on establishing, acquiring, investing in and developing financial services businesses, especially those involving new technologies connected with blockchain, distributed networks, digital assets, payments and lending. His work also includes advice to venture, private equity, credit and real estate fund managers on the structuring, establishment, and operation of their businesses and the marketing and distribution of their funds, including those marketed as ESG compliant.He has worked on regulatory change projects both for...

Web page updated on 22/05/2026

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