FCA Pilots ESG Ratings Reporting

UK regulators are moving closer to formal oversight of ESG ratings. For providers, the immediate issue is what supervisory reporting could require before the regime starts to apply.

The Financial Conduct Authority (FCA) has invited ESG rating providers to join a voluntary reporting pilot, with firms asked to register interest by 13 May 2026. It will test the information the FCA may need for supervision before future requirements become final Handbook rules.

The FCA is testing whether the proposed metrics can work across different business models and still give supervisors usable information.

A Pilot Before the Rulebook

On 28 April 2026, the FCA opened the pilot alongside CP25/34, ESG ratings: Proposed approach to regulation, published in December 2025. The consultation sets out the proposed rules for a newly regulated sector; the pilot examines how regulatory reporting could work in practice.

The FCA is using the pilot to test whether the proposed metrics can support supervision of risks, compliance and operational outcomes once the regime is live.

CP25/34 proposes a new framework for ESG rating providers. The Government is responsible for setting the scope of the FCA's regulatory perimeter, while the FCA is developing the rules for firms. The FCA says the Government is legislating to bring ESG rating providers within that perimeter.

Voluntary Test, Mandatory Regime

Participation in the pilot is voluntary. It is open to ESG rating providers that expect to be in scope of UK regulation, although the FCA may select a representative sample if interest is high. Data provided through the pilot is not intended to inform authorisation assessments.

The pilot also does not indicate final policy. The FCA says it may revise the metrics and will consult on regulatory reporting before those requirements become finalised Handbook rules.

The wider regulatory timetable is more formal. The CP25/34 consultation closed on 31 March 2026. The FCA expects to publish feedback and final rules in a Policy Statement in Q4 2026. The authorisations gateway is planned for June 2027, one year before the statutory regime goes live. Firms in scope must be authorised to carry out ESG ratings activity after 29 June 2028. CP25/34 also notes that some ESG ratings embedded in existing regulated activities sit outside the ESG ratings regime, so perimeter analysis remains part of preparation.

Operational Questions for Firms

For ESG rating providers, preparation starts with assigning owners and proving how a rating was produced. Firms will need to decide who is responsible for methodology governance, data quality, conflicts oversight, stakeholder engagement and regulatory reporting, including where parts of the ratings process are outsourced.

The evidence challenge is to connect each rating back to data sources, assumptions, weighting, corrections, quality checks and material methodology changes. CP25/34 also points to records sufficient to reproduce a rating, which raises the standard for internal documentation.

Disclosure work will need to cover methodology, data sources, AI use, conflicts and complaints in a form that is clear, accessible and not misleading. For rated entities, the proposed engagement rules make it important to know which ratings cover them, what data is being used and what evidence supports any factual correction.

Timing is the constraint. Authorisation preparation and disclosure readiness can begin now, but the reporting metrics will not be settled until after the pilot and a later consultation.

The Next Supervisory Signal

The pilot moves the discussion from policy design to implementation detail. Reporting teams should watch how FCA feedback from the pilot feeds into the formal consultation on regulatory reporting and the final rules expected in Q4 2026.

The next practical test is whether providers can show that their ratings are explainable, controlled and documented without disclosing trade secrets unnecessarily. For rated entities and users, the issue is whether the new information rights and disclosures make ratings easier to check before they are relied on.