35% of the UK’s largest platforms and advisory groups would fail the entity-level disclosure requirements that form part of the Financial Conduct Authority’s (FCA) new Sustainability Disclosure Requirements (SDR), according to a Mobilityways study.
All investment managers in excess of £5bn of assets under management will need to provide new disclosures to the FCA, explaining how they are managing sustainability risks and opportunities within a detailed annual Sustainability Entity Report, effective from 2 December 2025. Yet the Mobilityways Road to Net Zero study findings show that many asset managers, platforms and advisory firms would currently struggle to file those disclosures adequately.
Some 35% of firms it contacted had thus far failed to establish “some or all short- and medium-term milestones to help achieve net zero”, while over half (53%) of these large companies “had not even publicly stated a target date and year to reach net zero”.
Julie Furnell, managing director of Mobilityways, commented: “Although the financial services sector has proved to be ahead of some of the five sectors we researched for our extensive Road to Net Zero study, there is clearly no room for complacency, particularly now that the FCA’s SDR has set deadlines for new entity-level sustainability disclosures.
“There is no time to waste in setting targets, collecting reliable emissions data and developing solutions to decarbonise areas of their business’s operations. If they cannot get their own house in order in terms or environmental reporting and decarbonisation, they will have little credibility when they start promoting new ‘sustainability impact’ or ‘sustainability focus’ labelled funds to institutions or retail investors.”
Entity-level disclosures are likely to be built on the principles and recommendations laid out in the Taskforce on Climate-related Financial Disclosures (TCFD). ISSB, SASB and GRI Standards were also referenced by the FCA as documents to consider when building Sustainability Entity Reports.
However, the Mobilityways study found just 38% of sustainability leaders at large asset managers, adviser firms and distributors were using TCFD when asked about which emissions reporting framework they were using, despite it being the FCA’s preferred framework for completing the SDR’s new Sustainability Entity Reports.
Progress by these large asset managers and distributors in terms of their own Scope 1, 2 and 3 emissions reporting was also found to be patchy. Just over half (57%) had begun implementing Scope 1 and 2 ‘direct’ emissions reporting despite it sitting within TCFD recommendations.
Meanwhile, 71% have started implementing Scope 3 reporting covering indirect emissions from upstream and downstream ‘value chain’ activities such as their employees’ commutes and supplier emissions.
Of those that had begun Scope 3 reporting, however, just under half (48%) had fully implemented the Greenhouse Gas Protocol’s Corporate Value Chain (Scope 3) Accounting & Reporting Standard or equivalent. Additionally, 56% admitted that there were “significant gaps in provision of our organisation’s and suppliers’ environmental performance records”, and 59% were very concerned about “the lack of standardisation for weighting and measuring emissions performance”, especially in regards to Scope 3 reporting.
