FCA Engagement Papers 1-4: New regime for public offers and admissions to trading

ClientEarth urges the FCA to implement mandatory sustainability disclosures at the point of listing, aligned with TCFD and ISSB standards, to correct information asymmetry and protect investors from climate-related financial risks. The document specifically advocates for a new 'atmospheric viability' test for fossil fuel companies' reserves in Competent Person's Reports to address stranded asset risks. Additionally, it recommends extending these requirements to the debt market and introducing stricter, contractually binding disclosures for labelled bonds to prevent greenwashing and mispricing of climate risk.

• ClientEarth recommends that the FCA introduce mandatory sustainability disclosure requirements at the point of listing that align with TCFD, ISSB, and transition plan disclosures to address the "information asymmetry between issuers and the market".
• The document argues that existing voluntary frameworks for net zero targets and transition plans represent a "market failure" and that binding regulation is necessary to prevent greenwashing and "transition ‘in name only’".
• For 'mineral companies', ClientEarth proposes reforming the Competent Person's Report (CPR) to include a test for 'atmospheric viability', requiring companies to demonstrate that their reserves are consistent with science-based pathways to limit global warming to 1.5 degrees C.
• The report highlights a significant risk of 'unburnable carbon' on the London Stock Exchange (LSE), noting that emissions embedded on the LSE are 30 times greater than the UK's own fossil fuel reserves.
• ClientEarth advocates for the extension of mandatory sustainability and mineral company disclosure requirements to the debt market, noting that bonds are a primary funding source for high emitters and carry heightened credit risk from the energy transition.
• Regarding labelled bonds, the document recommends that the FCA adopt a more prescriptive approach (the 'Second Approach' in EP4) and require issuer-level covenants linked to transition plans to ensure climate promises are contractually binding.

APA

ClientEarth (2023). FCA Engagement Papers 1-4: New regime for public offers and admissions to trading. https://www.clientearth.org/media/1lrhaeg2/clientearth-response-to-fca-engagement-papers-29-9-23.pdf

Chicago

ClientEarth. FCA Engagement Papers 1-4: New regime for public offers and admissions to trading. 2023. https://www.clientearth.org/media/1lrhaeg2/clientearth-response-to-fca-engagement-papers-29-9-23.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=FCA Engagement Papers 1-4: New regime for public offers and admissions to trading |date=September 2023 |url=https://www.clientearth.org/media/1lrhaeg2/clientearth-response-to-fca-engagement-papers-29-9-23.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2023fca, author = {{ClientEarth}}, title = {{FCA Engagement Papers 1-4: New regime for public offers and admissions to trading}}, publisher = {ClientEarth}, year = {2023}, month = sep, url = {https://www.clientearth.org/media/1lrhaeg2/clientearth-response-to-fca-engagement-papers-29-9-23.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }