Cheat Sheet For Global Frameworks
Cheat Sheet For Global Frameworks
Cheat Sheet For Global Frameworks
frameworks
A list of the major regulatory and
voluntary global ESG frameworks
CSRD
EU
TAXONOMY
SDS
SFDR
Contents:
Part 1: ESG Regulation in the EU
Introduction:
EY estimates that there are over 600 ESG reporting standards worldwide. This
makes it incredibly difficult for companies and investors to deduce the most
Consolidation of frameworks and international support for the ISSB’s IFRS S1 and S2
frameworks, explaining what they are and, in the case of ESG regulation, who must
the main frameworks which govern our clients’ ESG ecosystem. For tailored guidance
on your specific compliance requirements, please get in touch with our compliance
experts.
TAXONOMY
What is it?
The EU taxonomy is a classification system that defines criteria for economic activities that
are aligned with net zero by 2050 and other environmental goals. It is a tool that supports
the EU’s sustainable finance framework to direct investments to the economic activities
most needed for the transition.
Companies based in the EU with more than 500 employees have an obligation to report
their alignment with the EU taxonomy.
Since January 2022, all in scope companies have needed to report the proportion of their
turnover, Capex, Opex, AUM (for asset managers) or Green Asset Ratio (for banks and credit
institutions) that is Taxonomy-eligible. Read more about what the EU taxonomy means for
asset managers/private equity funds here.
Since January 2023, all non-financial corporates must report the proportion of their
turnover, CapEx and OpEX that are taxonomy-aligned.
From January 2024, all financial firms must report the taxonomy alignment of their
investments, but only for investee companies that have reported their alignment.
For reporting in 2025, companies subject to CSRD are those that were already subject to EU’s
NFRD regulations.
For reporting in 2026, those that meet at least 2 of the following criteria must report:
For reporting in 2027, listed SMEs that meet at least 2 of the following criteria must also
report:
For reporting in 2029, non-EU companies that generate net turnover of over €150mn will be
subject to reporting requirements.
All FMPs in the EU, or those marketing themselves in the EU must report. FMPs include:
The products that it encompasses include (not exhaustive): investment and mutual funds,
UCITS, insurance-based investment products, private and occupational pensions and
insurance and investment advice.
In 2022, the UK implemented regulations based on the TCFD framework for asset owners,
managers and companies. The TCFD framework follows four pillars: governance, strategy,
risk management and metrics and targets. This is a continuously evolving space because,
with the news that the ISSB has incorporated the TCFD into their IFRS S1 and S2 standards,
the UK has announced that their new Sustainability Disclosure Standards will follow IFRS
S1 and S2 guidelines.
While there was a tiered calendar of TCFD implementation depending on the type of
entity listed below, all are now under the scope of regulatory reporting. Entities included in
the regulations are:
· Large UK companies that are either publicly traded, banking companies, insurance
companies, or companies that have more than £500mn in annual turnover and have more
than 500 employees
· Traded LLPs, banking LLPs or LLPs with more than £500mn in annual turnover and more
than 500 employees
Read this article to find out how TCFD is relevant to private equity fund managers.
SDR
What is it?
The Sustainability Disclosure Requirements (SDR) are product labelling and naming and
mixed goals’. They set the rules for financial market participants, outlining disclosure
All FCA-authorised firms that make sustainability-related claims about their products and
Read this article to find out about the finalised SDR regulations.
SDS SDS
What is it?
The Sustainability Disclosure Standards (SDS) will set out corporate disclosures on the
sustainability-related risks and opportunities that companies face. They will be based on
the ISSB’s IFRS S1 and S2 standards, with the UK government’s secretary of state for
business and trade aiming to endorse the first set of standards by July 2024.
To be confirmed.
The SEC has proposed mandating certain climate-related disclosures such as climate
risks for publicly listed companies. The proposal is aligned with the TCFD framework and
could include GHG emissions (scope 1, 2 and 3), disclosure of climate-related risk, impacts,
targets and goals, systematic management of offsets and REC’s and the articulation and
management of a transition plan. This initiative is under threat, however, from Republican
lawmakers that have argued it would be burdensome for corporates, especially calculating
scope 3 emissions. The disclosure requirements do not currently have a set date for
finalisation.
To be confirmed
California Climate
disclosure laws
What are California’s climate disclosure laws?
California has jumped ahead of the SEC climate disclosures and implemented its own
laws. The bills require GHG emissions reporting in compliance with the GHG Protocol,
climate-related financial risk reporting in line with the TCFD and disclosure of information
about certain emissions claims and the sale and use of carbon offsets.
Any US business, both public and private, with total annual revenues exceeding $1bn that
is ‘doing business’ in California. Scope 1 and 2 emissions reporting will be required annually
from 2026, and scope 3 in 2027.
US companies exceeding $500mn in total annual revenues that are ‘doing business’ in
California will have to disclose climate-related financial risk reports, in line with TCFD.
Reports must be submitted by 1st June 2026.
disclosure laws
What are California’s VC diversity laws?
A covered entity must report the following demographic information for the founding
teams of all portfolio companies in which the covered entity invested in the prior calendar
year (to the extent the information was provided pursuant to the survey described below):
gender identity, including non-binary and gender-fluid identities, race, ethnic identity,
disability status, veteran status, whether such person identifies as LGBTQ+ and whether
such person is a California resident, at an aggregated level and on an anonymised basis.
Covered entities also must report the total amount of investments in the prior calendar
year in portfolio companies that were primarily founded by diverse founding teams (i.e.,
where at least half of the founding team is made up of people of diverse backgrounds and
perspectives), as a percentage of venture capital investments made by the covered entity,
in the aggregate and broken down according to the demographic categories listed above,
as well as the total amount of money in venture capital investments the covered entity
invested in each portfolio company during the prior calendar year and the principal place
of business of each portfolio company in which the covered entity made an investment
during the prior calendar year.
The information should be collected via a standardised survey, established by the California
Civil Rights Department (CRD).
Any venture capital firm operating in the state (that includes VC firms headquartered in
California, have operations in the state, have invested in companies that operate in or are
based in the state, or have received investments from California residents) must report. As
it currently stands, the first report will be due on March 1, 2025
IFRS S1 and S2
What is it?
The International Sustainability Standards Board (ISSB) was formed in 2021 at COP 26
and is the first sustainability framework to generate widespread international support,
coming from the G7, G20, and various global finance ministers. The ISSB has consolidated
various ESG framework bodies in the past few years, including the Sustainability
Accounting Standards Board (SASB), the Climate Disclosure Standards Board (CDSB) and
the Taskforce for Climate-related Financial Disclosures (TCFD). They have created the IFRS
S1 and S2 standards which more than 20 regulators issued support statements for, with
countries such as the UK, Brazil, Canada, Mexico, Singapore, Hong Kong and Japan set to
adopt the standards.
EDCI
What is it?
The Institutional Limited Partners’ Association’s ESG Data Convergence Initiative (EDCI)
is a collaborative effort by the private equity industry to establish a common framework of
ESG metrics to aid comparability and harmonise LP data requests. EDCI has over 375
members with $28tn in AUM and 4,300 portfolio companies included in its benchmarks. It
comprises the leading ESG reporting standards in the private equity industry.
Read this article for more information on the EDCI and the benefits of its benchmark
data.
PRI
What is it?
There are over 5,000 signatories of the Principles for Responsible Investment. They are
· Organisational overview
· Listed equity
· Fixed income
· Real estate
· Infrastructure
· Private equity
· Hedge funds
· Confidence-building measures
GRI
What is it?
with businesses and investors to help them understand their impacts. It incorporates the
double materiality approach, like CSRD, and is used by over 10,000 organisations in over
100 countries.
WEF
The World Economic Forum published its set of ESG metrics in 2020 to help with
B Corp
What is it?
B Corp started out in the US, where ‘benefit corporation’ is a legally recognised corporate
entity that has goals of making a profit alongside a positive impact on society. Having
expanded the concept beyond the US, non-profit B lab has made B Corp a globally
verified environmental and social performance, accountability and transparency. You may
recognise the logo and have seen it on your favourite consumer goods in the supermarket,
for example. To meet requirements, companies must reach a minimum in their B Impact
assessment score of above 80, make a legal commitment by changing their corporate
UN SDGs
UN SDG
What is it?
The Sustainable Development Goals (SDGs), also known as the Global Goals, were
adopted by the United Nations in 2015 as a universal call to action to end poverty, protect
the planet, and ensure that by 2030 all people enjoy peace and prosperity.
The 17 SDGs are integrated—they recognize that action in one area will affect outcomes in
others, and that development must balance social, economic and environmental
sustainability. UNDP, the UN’s development agency, plays a critical role in helping
countries achieve the SDGs. Although not designed for investors, many fund managers
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