Aviva is pleased to have responded to the FCA Consultation Paper (CP) on Sustainable Disclosure Requirements and investment labels (CP22/20)
Back in October (2022), we welcomed the publication of this CP and over the recent month’s we have considered its detail - FCA Consultation Paper on Sustainable Disclosure Requirements and investment labels (CP22/20) - Aviva (avivab2b.co.uk)
Aviva applauds the FCA for its hard work and unrelenting efforts to create a sustainable funds regime in the UK that would “advance the FCA’s strategic objective to make markets function well, by increasing transparency on the sustainability profile of products and firms and reducing the risk of harm arising from greenwashing” (CP22-20 FCA, p.6). We too believe in the importance of shoring up trust in sustainable investing, in protecting investors from the threat of greenwashing and in supporting investors to identify products that align to their preferences, including in relation to sustainability. Given the challenges inherent in this important work, we welcome FCA’s proposals to carry out a post-implementation review after three years to assess how the labelling regime has bedded in. We are also supportive of the FCA’s proposal to assess the usefulness of the labels and product-level information to consumers through the FCA’s Financial Lives Survey and through engagement with consumer groups. Building in mechanisms to review and measure success is critical. Acting on the findings of these reviews helps to support the delivery of an approach that can continue to be fit for purpose for investors, as the market and broader policy environment evolve over time.
We thank FCA for its continued dialogue on this important area, and we look forward to providing on-going constructive input as the proposed rules inevitably evolve to their final state in Summer 2023.