Home FCA Handbook ESG ESG 2 ESG 2.3 Product-level reporting
You are viewing ESG 2.3 Product-level reporting as of . ESG 2.3 Product-level reporting was last updated on 25/09/2026.

ESG 2.3 Product-level reporting

Communicating with retail clients

25/09/2026R

ESG 2.3.1BR to ESG 2.3.1CG apply to a firm which is undertaking TCFD in-scope business under ESG 1A.1.1R for a retail client, either:

  1. (1) in relation to managing an authorised fund that is not a feeder fund. This includes, where the authorised fund is an umbrella scheme, each sub-fund within that umbrella;
  2. (2) as an insurer or pure reinsurer, in relation to providing or operating an insurance-based investment product, personal pension scheme, stakeholder pension scheme or SIPP with respect to:
    1. (a) a with-profits fund;
    2. (b) a linked fund; or
    3. (c) a pre-set investment portfolio;
  3. (3) otherwise than as an insurer or pure reinsurer, in relation to operating a personal pension scheme, stakeholder pension scheme or SIPP with respect to:
    1. (a) an authorised fund;
    2. (b) a closed-ended investment fund; or
    3. (c) a pre-set investment portfolio; or
  4. (4) in relation to managing an unauthorised AIF which is listed on a recognised investment exchange (including an investment trust) unless it is:
    1. (a) a closed-ended AIF that makes no additional investments after 22 July 2013 (see regulation 74(1) of the AIFMD UK Regulation);
    2. (b) a SEF; or
    3. (c) an RVECA.
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  1. (1) A firm must periodically consider whether climate-related risks could be materially relevant to the financial performance or return of a product which the firm manages, operates or provides under ESG 2.3.1AR.
  2. (2) Where a firm produces communications for retail clients which provide general information on the risk and financial returns of a product, it must include in those communications any climate-related risks it has identified under (1).
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  1. (1) A firm should undertake its obligations under ESG 2.3.1BR(1) in a manner and with a frequency which is appropriate for that product and may choose to do so as part of the firm’s usual risk assessment procedures.
  2. (2) For the purposes of ESG 2.3.1BR(2), a firm may, where applicable, choose to disclose climate-related risks as part of the risk and return information contained in a product summary. 

Communicating with institutional clients

25/09/2026R

ESG 2.3.5AR to ESG 2.3.7AG apply to a firm which is undertaking TCFD in-scope business under ESG 1A.1.1R for a client or a person in relation to:

  1. (1) the products the firm manages, operates or provides under ESG 2.3.1AR;
  2. (2) the investments, including rights to or interests in investments, in respect of which the firm provides portfolio management to a client; or
  3. (3) the assets under management in an unauthorised AIF, in which the client or person is an investor, managed by a full-scope UK AIFM or a small authorised UK AIFM which is not listed on a recognised investment exchange.
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  1. (1) Where a client or a person requires climate-related information in order to satisfy their legal or regulatory climate-related financial disclosure obligations, a firm must, on request, provide to that client or person, at a minimum, data on scope 1, 2 and 3 greenhouse gas emissions as required to meet that client’s or person’s climate-related financial disclosure obligations.
  2. (2) The obligation in (1) applies to a firm in relation to 1 request for information from a client or a person per calendar year in relation to each of the products the firm operates, manages or provides under ESG 2.3.4AR.
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If a client or person requests additional information to that provided under ESG 2.3.5AR(2), a firm should provide the following information if doing so is reasonably practicable and permitted under any contractual arrangements governing the firm’s use of the data:

  1. (1) climate or carbon-related data which is reasonably required in order to satisfy the client’s or person’s climate-related financial disclosure obligations; and/or
  2. (2) an explanation of the proportion of each product for which data is verified, reported, estimated or unavailable.
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A firm should pay due regard to the information needs of a client or a person and communicate information to them in a way which is clear, fair and not misleading. For example, a firm should:

  1. (1) provide the information to a client or person within a reasonable period of time;
  2. (2) provide the information to a client or a person in a format in which the firm, acting reasonably, considers appropriate;
  3. (3) provide contextual information where relevant, such as an explanation as to how certain data and information should be interpreted and any associated limitations; and 
  4. (4) refrain from providing information which, in the reasonable opinion of the firm, is misleading due to data gaps or methodological challenges which cannot be addressed using proxy data or assumptions.