FCA Consultation CP21/17: Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers

ClientEarth responds to the FCA's CP21/17 consultation, arguing that while the proposed expansion of climate-related disclosures is welcome, the FCA must broaden the scope of regulated firms, mandate Paris-aligned transition plans, and ensure robust enforcement to meet the UK's net-zero targets.

• ClientEarth recommends that the scope of entity-level TCFD reports be expanded to all FCA-regulated firms regardless of size, removing the current £5 billion assets under management (AUM) threshold for asset managers, life insurers, and pension providers.
• The document argues that transition plans must be explicitly aligned with the Paris Agreement's 1.5°C goal and the UK Government's emissions reduction commitments, including specific targets to reduce emissions by 68% by 2030 and 78% by 2035 compared to 1990 levels.
• ClientEarth proposes that the FCA accelerate the implementation timeline, requiring all in-scope companies to adopt the new rules for periods beginning January 2022, rather than the proposed phased approach extending to some firms in January 2023.

APA

ClientEarth (2021). FCA Consultation CP21/17: Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers. https://www.clientearth.org/media/fuuputwb/clientearth-response-to-fca-cp21-17-final.pdf

Chicago

ClientEarth. FCA Consultation CP21/17: Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers. 2021. https://www.clientearth.org/media/fuuputwb/clientearth-response-to-fca-cp21-17-final.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=FCA Consultation CP21/17: Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers |date=September 2021 |url=https://www.clientearth.org/media/fuuputwb/clientearth-response-to-fca-cp21-17-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021fca, author = {{ClientEarth}}, title = {{FCA Consultation CP21/17: Enhancing climate-related disclosures by asset managers, life insurers, and FCA-regulated pension providers}}, publisher = {ClientEarth}, year = {2021}, month = sep, url = {https://www.clientearth.org/media/fuuputwb/clientearth-response-to-fca-cp21-17-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }