PS26/22: ESG ratings: final regime

For compliance teams, this is not just a disclosure update: it creates a new regulated activity and requires early perimeter assessment against the final PERG guidance. Providers should test whether their ratings, data products or related services fall in scope, then complete a gap analysis against FCA baseline and tailored requirements covering transparency, methodology, governance, conflicts, records and comparability. Firms using ESG ratings—banks, insurers, pension funds, asset managers and wealth managers—should review third-party reliance, procurement and investment decision frameworks to manage data quality and greenwashing risk.

The regime aligns with IOSCO recommendations and supports confidence in sustainable finance, but it raises barriers to entry and compliance costs. Action now: assign ownership, assess authorisation needs, engage with the FCA, update policies and contracts, and prepare evidence for supervisory review. Early movers may gain advantage as trusted, comparable providers; unprepared firms face permission delays and reputational risk.