On 12 December 2024, the EU Regulation on ESG Ratings Providers and their transparency and integrity was published in the Official Journal of the European Union (the “Regulation”).
It means that the Regulation will enter into force on 2 January 2025 (20 days after publication in the Official Journal of the European Union) and will apply from 2 July 2026.
The Regulation introduces a regulatory regime for ESG rating providers operating in the EU (and therefore does have extra-territorial reach). It is broadly drafted in parts and there could be unexpected capture of asset managers, particularly where ESG ratings and scores are used in ESG-related investment strategies and information on this is published in marketing materials.
For further information, please reach out to ukreg@proskauer.com