The UK’s SDR naming and marketing rules have applied since 2 December 2024, and the extra time the FCA gave a small group of funds runs out at 5pm on 2 April 2025. If you manage UK funds with “sustainable”, “sustainability” or “impact” in their names, the coming month is when the label, the new name or the new documents need to go live, and if you’re relying on the flexibility but aren’t certain it covers you, it’s worth checking now.
What is SDR?
The FCA’s Sustainability Disclosure Requirements (SDR), set out in PS23/16 in November 2023, are the UK’s rules on sustainability labels, fund naming, marketing and disclosure, and they have been arriving in stages:
- 31 May 2024: the anti-greenwashing rule, which applies to every FCA-authorised firm
- 31 July 2024: the four investment labels became available, namely Sustainability Focus, Sustainability Improvers, Sustainability Impact and Sustainability Mixed Goals
- 2 December 2024: the naming and marketing rules, and the disclosures that go with them, for funds using sustainability-related terms without a label, plus a notice that distributors must show on overseas funds
- 2 December 2025: entity-level disclosures for the largest firms, those with over £50 billion of assets under management, followed a year later by firms with over £5 billion
What do the SDR naming and marketing rules require?
Labelled funds have the most freedom, because a fund with a label can use sustainability-related terms in its name. The one restriction is that a fund using the Focus, Improvers or Mixed Goals label can’t use the word “impact”. For labelled funds the bar is higher in other ways, though, since under ESG 4.2 they need an explicit sustainability objective and at least 70% of gross assets invested in line with it.
Under ESG 4.3.5R, a fund without a label can still use sustainability-related terms in its name, but only if it has sustainability characteristics and the name accurately reflects them. The FCA’s guidance says those characteristics should be material, for example with at least 70% of assets having sustainability characteristics. Three words are reserved, though: an unlabelled fund can’t use “sustainable”, “sustainability” or “impact”, or variations of them, in its name to describe its sustainability characteristics.
An unlabelled fund using these terms also needs a consumer-facing disclosure, a pre-contractual disclosure and an ongoing product-level report. On the webpage where the fund is offered, the manager must explain what labels are for, state “This product does not have a UK sustainable investment label”, and briefly say why.
Marketing has to match the fund as well, so financial promotions must be consistent with its label, if it has one, and with its disclosures. Using sustainability terms in a promotion for an unlabelled fund triggers the same disclosure and web statement duties.
Who does the 2 April flexibility cover?
In September 2024 the FCA announced limited temporary flexibility, after it became clear that some firms needed more time to get labels approved or change fund names. The flexibility is narrow, applying only to a UK authorised fund where the firm:
- submitted a completed application for approval of amended disclosures by 5pm on 1 October 2024, and
- uses “sustainable”, “sustainability” or “impact” (or a variation) in the fund’s name, and intends either to use a label or to change the name
It doesn’t cover funds using other sustainability-related terms, and it doesn’t switch off anything else. The anti-greenwashing rule still applies, and the FCA expects firms that can comply sooner to do so rather than waiting for April.
How far has the market moved on SDR labels?
The FCA’s own figures give a sense of the pace. As at 16 January 2025, 43 funds had notified the FCA that they intend to use a label, and the FCA had approved pre-contractual disclosures for a further 57 authorised funds. It hadn’t contacted any fund about breaches of the naming and marketing rules, which is what you’d expect while the flexibility is still running.
What it means in practice
For funds inside the flexibility, 2 April is a fixed switch date. By then each fund needs to be either labelled, with its consumer-facing and pre-contractual disclosures live, or renamed to drop the reserved words, with the unlabelled disclosures and web statement in place.
Either way, the change ripples outwards, because a new name or a new label has to appear in the prospectus, the KIID, factsheets, fund webpages, platform data feeds and marketing at the same moment. A factsheet still carrying the old name after 2 April is exactly the kind of inconsistency the anti-greenwashing rule is designed to catch.
When do the SDR deadlines fall?
- 28 November 2023: PS23/16 is published
- 31 May 2024: the anti-greenwashing rule comes into force
- 31 July 2024: the labels become available
- 9 September 2024: the FCA announces temporary flexibility
- 1 October 2024: deadline to apply for approval of amended disclosures in order to qualify
- 2 December 2024: the naming and marketing rules come into force
- 5pm, 2 April 2025: the temporary flexibility ends
- 2 December 2025: entity-level disclosures begin for firms with over £50 billion AUM
What should investment managers do now?
- Confirm that each fund relying on the flexibility met the 1 October application condition and uses one of the three reserved words.
- Agree one go-live date per fund for the label or new name, and apply it across every document and channel.
- Review unlabelled funds outside the flexibility, which have been in scope since December, testing their names, the 70% guidance, the disclosures and the web statement.
The flexibility gave firms more time rather than a different standard, so from 2 April the name on each fund needs to match what’s in it wherever that name appears.
At Kurtosys we help investment managers keep fund data governed, so a fund’s name, label and sustainability disclosures flow consistently into prospectuses, KIIDs, factsheets, client reports and fund websites. When a name or label changes on a set date, that’s one controlled update to the data rather than a scramble across documents. If you’d like to talk through what SDR means for your fund range, get in touch.
Sources: FCA: FCA sets out temporary measures for firms on naming and marketing sustainability rules, FCA PS23/16: Sustainability Disclosure Requirements and investment labels, FCA Handbook: ESG 4.3, FCA: Information on SDR, January 2025, as at 1 March 2025.
About this article
This article reflects the position at 1 March 2025 and was checked against the primary sources available at that time. Thomas Bjerkén, our regulatory reporting and fund data specialist, joined Kurtosys after it was published and now looks after our regulatory content. Some details may have changed since it was published.
