Rita Hunter

Sustainability-related disclosures:EU SFDR v UK SDR

The EU Sustainable Finance Disclosure Regulation ((EU) 2019/2088) (SFDR) and the EU Taxonomy Regulation and the UK Sustainable Finance Disclosure Requirements (SDR) and labelling regime both aim to increase transparency, investor protection and disclosure around sustainable finance products and the climate impact of investments. Both the SFDR and SDR and emerging regimes in the US and internationally are designed to meet market concerns around the need for improved climate disclosure requirements. In this article, we seek to compare the key themes and features of the SFDR and SDR to determine possible areas of divergence and convergence particularly for those firms who need to consider the applicability of both the UK and EU requirements to their products and services. We set out below a recap of both regimes and significant areas of difference between the two UK and EU regimes in particular.