Do you provide ESG ratings that may inform investment decisions?
From 29 June 2028, providing certain environmental, social and governance (ESG) ratings will become a regulated activity overseen by the Financial Conduct Authority (FCA).
RICS is considering whether there may be a need for a regulatory route for eligible RICS firms under our existing status as a Designated Professional Body (DPB). We have not made a decision to introduce such a route.
Before deciding whether to take this work any further, we want to understand whether RICS-regulated firms are currently carrying out, or expect to carry out, activities that could fall within the new ESG ratings regime.
The regime can apply to providers based in the UK even where they provide ESG ratings to clients outside the UK. It can also apply in some circumstances to providers based overseas where they supply ESG ratings into the UK.
What type of activity are we asking about?
The new regime is specifically concerned with the provision of ESG ratings. It does not apply merely because a firm provides ESG or sustainability advice or takes ESG considerations into account in its professional work.
Broadly, the activity we are interested in is where a firm itself produces and makes available an assessment of one or more environmental, social or governance factors which:
- is expressed as an opinion, a score or a combination of both;
- is prepared using an established methodology;
- uses a defined ranking system of rating categories, such as scores, grades, letters, colours or other categories which allow rated items to be distinguished or ranked; and
- is likely to influence a decision about a specified financial investment.
A service can potentially meet this description even where the firm does not call it an “ESG rating”. For example, a sustainability score, transition score, resilience assessment or other similarly ranked assessment may be relevant if it has the characteristics above.
Conversely, simply providing ESG information or data does not make something an ESG rating. The FCA has explained that data which is not linked to a defined ranking system is not, by itself, an ESG rating.
What if we provide valuation or sustainability services?
You do not need to complete the survey solely because your firm considers ESG or sustainability factors as part of its usual professional work.
For example, firms undertaking Red Book valuations may take sustainability and ESG matters into account where they are relevant to value. Taking those matters into account does not, by itself, mean that the firm is providing an ESG rating for the purposes of the new regime.
Similarly, general sustainability, environmental or climate-related advice will not necessarily amount to an ESG rating.
However, the position may be different where, as part of or alongside those services, a firm produces a separate ESG or sustainability score, rating or other ranked assessment using an established methodology. If that describes your firm’s activities, we would like to hear from you.
We would like to hear from you if:
- your firm currently produces ESG ratings of the type described the above;
- your firm expects or is considering providing this type of service in future;
- your firm produces a scored or ranked ESG or sustainability assessment and you are unsure whether it may fall within the new regime; or
- your firm may be interested in a potential RICS regulatory route for this activity.
Please complete our short survey. It should only take a few minutes.
The information we receive will help RICS understand whether there is a population of RICS firms potentially affected by the new regime and whether there is a case for doing further work on a possible RICS regulatory route.
Completing the survey does not mean that RICS considers your firm or its activities to fall within the FCA’s regulatory perimeter. Firms will ultimately need to consider the legislation and FCA guidance in determining whether their activities are within scope.
Further information
For further information about the new regime, including the FCA’s proposed approach and guidance on which activities may fall within scope, see the FCA’s ESG ratings consultation page.
FCA: ESG ratings – proposed approach to regulation
The FCA consultation has now closed and the FCA expects to publish its Policy Statement and final rules in Q4 2026. The new regime is due to come into effect on 29 June 2028.