Sustainability

Recent Articles

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  20/05/2025

  EU Benchmarks Regulation Overhaul Published

  The long awaited overhaul of Regulation (EU) 2016/1011 (“EU BMR”) was published on the 19th May 2025. Regulation (EU) 2025/914 (the “EU BMR Amending Regulation”)  amends and updates EU BMR to conduct a significant overhaul of the regime.Executive SummaryThe key focus of amendments are changes in-scope leading to a significant net reduction in benchmarks subject to the EU BMR. Notably:reducing the scope of the EU BMR so it only applies to critical and significant benchmarks, EU Climate Transition and EU Paris-Aligned benchmarks (“EU Climate Benchmarks”) and...

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  08/05/2025

  PRA Updates Climate Risk Expectations

  On 30 April, the PRA published consultation paper CP10/25 on proposed updates to its Supervisory Statement on Climate Risk (SS3/19). The proposals are relevant to insurers, banks, building societies, and PRA-designated investment firms.The PRA notes that progress since SS3/19, published in 2019, has been uneven and it believes that more needs to be done to meet the expectations. Conversely, firms have asked the PRA to provide greater clarity on what the PRA expects them to do to manage the effects of climate change.The PRA also emphasises the features of climate-related risks that require a strategic...

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  07/05/2025

  European Commission publishes Call for Evidence on SFDR revision

  On 2 May 2025, the European Commission (“EC”) published its call for evidence to help form an impact assessment on the revision of the EU Sustainable Finance Disclosure Regulation (“SFDR”).The Call for Evidence, which follows the Platform on Sustainable Finance’s briefing note outlining its proposal for a new categorisation system under the SFDR (which you can read more about here), invites stakeholders to submit general feedback.The Call for Evidence states that due to a lack of legal clarity on key concepts, the limited relevance of certain disclosure requirements,...

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  07/05/2025

  EU ESG Ratings Regulation – What do I need to do if I’m not a ratings provider?

  The EU ESG Ratings Regulation (“ESGRR”) entered into force on 2 January 2025 and will start applying from 2 July 2026.The ESGRR is primarily aimed at firms that aim to explicitly position themselves as an ESG ratings provider.However, the broad scope of the ESGRR will impact other firms who may not think of themselves as an ESG ratings provider. It is therefore a key compliance issue for other types of firms (both EU and non-EU) to consider.Executive SummaryEven where a firm is not intending to operate as an ESG ratings provider, it will need to carefully consider whether ESG related...

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  06/05/2025

  Financial Services Webinars On Demand

  View recordings of CMS financial services webinars available on demand.Webinars are a convenient way to stay informed and hear from our legal experts.Webinars On Demand

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  06/05/2025

  ESMA Consultation Paper on RTS under the ESG Ratings Regulation

  On 2 May 2025, the European Securities and Markets Authority (“ESMA”) published a Consultation Paper on regulatory technical standards (“RTS”) under the ESG Ratings Regulation (“ESGRR”).It contains draft RTS on:applications for authorisation and recognition of ESG ratings providers (“Authorisation and Recognition RTS”);measures and safeguards that should be put in place to mitigate conflicts of interest in separating business and activities other than the provision of ESG ratings (“Separation of Business RTS”); andinformation to be disclosed...

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