FCA Referral Request

ClientEarth has submitted a referral request to the Financial Conduct Authority (FCA) alleging that Carnival plc and Carnival Corporation failed to disclose material climate-related financial risks in their 2020 reporting. The request argues that the companies' reports are vague or entirely silent on climate change, potentially misleading investors and violating Disclosure Guidance and Transparency Rules (DTRs) and the UK Market Abuse Regulation (UK MAR). ClientEarth specifically challenges Carnival's reliance on Liquefied Natural Gas (LNG) as a decarbonisation strategy, noting that such claims are not substantiated in financial statements and ignore methane emissions and the UK Climate Change Committee's findings on biofuels. The referral seeks financial penalties, public censure, and corrective disclosures.

• The 'Carnival Corporation & plc 2020 Annual Report' contains no mention of climate change, while the 'Strategic Report and IFRS Financial Statements for the year ended 2020' provides only vague statements that lack 'decision useful' analysis.
• Carnival's claims regarding its commitment to decarbonisation through the use of Liquefied Natural Gas (LNG) and bio-LNG are described as potentially misleading because they omit the environmental impacts of natural gas, such as methane emissions, and contradict UK Climate Change Committee analysis on the efficacy of biofuels in shipping.
• Carnival plc is alleged to be in breach of several FCA Handbook rules, specifically DTRs 1A.3.2R, 4.1.8R, LR 1.3.3R, and LR9.8.6(3)R, due to the omission of material climate risks and the provision of potentially misleading information.
• The document asserts that Carnival plc's financial statements fail to consider climate change risks and impacts, suggesting a potential breach of DTR4.1.7R and the Companies Act 2006, and implies that auditors PriceWaterhouseCoopers LLP may have failed in their audit obligations.
• ClientEarth argues that the failure to disclose climate-related information may constitute market manipulation under the UK Market Abuse Regulation (UK MAR) if such omissions significantly affect the price of Carnival's shares or related derivative instruments.

APA

ClientEarth (2021). FCA Referral Request. https://www.clientearth.org/media/r2ymeh5o/17-08-2021-clientearth-fca-referral-request-carnival-plc-and-carnival-corporation.pdf

Chicago

ClientEarth. FCA Referral Request. 2021. https://www.clientearth.org/media/r2ymeh5o/17-08-2021-clientearth-fca-referral-request-carnival-plc-and-carnival-corporation.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=FCA Referral Request |date=17 August 2021 |url=https://www.clientearth.org/media/r2ymeh5o/17-08-2021-clientearth-fca-referral-request-carnival-plc-and-carnival-corporation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021fca, author = {{ClientEarth}}, title = {{FCA Referral Request}}, publisher = {ClientEarth}, year = {2021}, month = aug, url = {https://www.clientearth.org/media/r2ymeh5o/17-08-2021-clientearth-fca-referral-request-carnival-plc-and-carnival-corporation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }