Reporting requirements for a financial services firm do not stop at the annual report and accounts. Firms must meet regulatory reporting requirements too. Disclosure of information on sustainability risks is vital to enable stakeholders, including regulators, to make-well informed decisions about institutions' sustainability exposures, risks and strategies.
This could take the form of private reporting via regulatory returns or public reporting. In Europe, the EBA published binding Pillar 3 disclosure technical standards for ESG risks last year and we are seeing the first wave of reporting in 2023.
At an investment level, firms may already need to comply with the EU's Sustainability Finance Disclosure Regulation (SFDR) and the linked EU Taxonomy for product level and entity level disclosures. Again, they will need to consider the extent of overlap with other emerging regulations.
In the UK, the Sustainable Disclosure Regulation (SDR) is taking shape, with new anti-greenwashing rules applying from June 2023 for all FCA-regulated firms and product level and entity level disclosures expected for asset managers from June 2024. A new UK green taxonomy, likely to be modelled to some extent on its EU counterpart, is under discussion and once established will be incorporated into reporting requirements.
The intersections between corporate, product and entity level disclosures for regulatory or other purposes, and the need to consider potentially differing sustainability taxonomies, present a significant challenge to financial services firms today and will continue to do so. Complying with each of the standards may be tactical at first due to the sheer volume of requirements.
But the aspiration should be to get ahead and weave the requirements together adopting a sustainability reporting strategy that ensures optimal and efficient implementation to drive both transparency and consistency. Effective reporting will depend on embracing the complexities and having a proactive and strategic approach.
Persisting with a tactical approach comes with inherent risks, including the risk of greenwashing, that could compromise the credibility of firms' reporting and their broader reputation.