ESG Rating Providers Come Under FCA Rules: What Asset Managers Should Check In Their Data

ESG rating providers assess how companies, assets or products perform against environmental, social and governance criteria, and asset managers use those ratings in investment decisions and reports. On 3 November 2026 the FCA published final rules that bring these providers into UK regulation for the first time.

What did the FCA announce for ESG rating providers?

The FCA said the framework is designed to improve the transparency, reliability and comparability of ESG ratings. It introduces requirements on transparency, governance, systems and controls, the management of conflicts of interest, and engagement with users of ratings and rated entities, in proportion to a firm's size and activities. The FCA said the regime regulates how ratings are produced, governed and communicated, and does not prescribe a particular sustainability view or method.

ESG rating providers operating in the UK market will need to apply for authorisation from 24 June 2027, and the framework takes effect on 29 June 2028. Laura Dawes, director of authorisations and sustainable finance at the FCA, said: “Firms should check now whether they are in scope and start preparing for authorisation.”

ESG ratings regime timeline. Source: FCA, 3 November 2026.

Date	Milestone
October 2025	Government legislation brings ESG ratings within the FCA's remit
1 December 2025 to 31 March 2026	FCA consultation CP25/34
3 November 2026	Final rules published
24 June 2027	Providers can apply for authorisation
29 June 2028	Framework takes effect

The FCA said the approach is shaped by international standards, including recommendations from the International Organization of Securities Commissions (IOSCO). It added that 95% of respondents to the government's consultation supported bringing ESG ratings into regulation.

What does it mean for asset managers?

• **Better information at the source.** Providers will need to be clearer about how ratings are made.
• **Your own checks stay yours.** How ratings are loaded, mapped to holdings and shown in reports is your process.
• **Changes become visible.** With more transparency from providers, method changes should be easier to spot and explain to clients and boards.

What should asset managers check each month?

• **Coverage.** Every holding that should have a rating has one, and gaps are listed.
• **Changes.** Ratings that moved since last month, with the size of each move.
• **Source.** Which provider and which version each figure came from.
• **Reports.** Figures in client reports and board packs match the loaded data.

When a provider changes its method, many ratings tend to move at once. A short note in the pack explaining the change saves a question from the board later.

How can workflow automation help with ESG data?

The checking is routine: compare this month's ratings with last month's, flag holdings whose rating changed or went missing, and note which provider and version each figure came from. Our MI and board packs workflow prepares this kind of comparison and drafts the notes, and the pack owner approves every number before it goes out. Our article on private markets conflicts of interest covers another FCA focus for asset managers.

Where should an asset manager start?

List which ESG ratings you use, from which providers, and where each one appears in your reports. A 14-day Proof Run can automate the month-on-month comparison on your own data. This article summarises an FCA publication and is not regulatory advice.