FCA authorisation for ESG ratings providers

Key points

  • Providing an ESG rating that is likely to influence an investment decision becomes a regulated activity on 29 June 2028, under the ESG Ratings Order 2025 (SI 2025/1349).
  • The FCA published its final rules in PS26/22 on 3 November 2026.
  • Firms projecting £500,000 or more of ESG ratings revenue in the 12 months after applying apply between 24 June and 29 July 2027. All other firms apply between 30 July and 31 August 2027.
  • Pre-application meetings are available from February 2027 through the FCA's Pre-Application Support Service.
  • Overseas providers are in scope when their ratings reach UK customers, unless the rating is given to the UK customer free of charge.
  • Exclusions cover ratings inside activities the FCA already regulates, benchmarks, credit ratings, proxy advice, intra-group use and occasional unpaid provision by charities, academics and journalists.
On this page

From 29 June 2028, firms that provide ESG ratings in the UK need authorisation from the Financial Conduct Authority. The FCA published its final rules in PS26/22 on 3 November 2026. Applications open on 24 June 2027, in two windows set by each firm's projected ESG ratings revenue.

This is a new licence, not a change to an existing one. Most ESG ratings providers have never been regulated by the FCA, so the work starts with the basics: confirming the firm is in scope, choosing the legal entity that will apply, and building the governance and controls the FCA expects of any authorised firm.

The dates

DateWhat happens
3 November 2026FCA publishes final rules and perimeter guidance in PS26/22
7 December 2026FCA webinar on the policy statement and the new regime
26 January 2027FCA webinar on the authorisation process and pre-application support
February 2027Pre-application meetings available through the Pre-Application Support Service
24 June to 29 July 2027First application window: firms projecting £500,000 or more of ESG ratings revenue
30 July to 31 August 2027Second application window: all other firms
29 June 2028The regime takes effect; providing ESG ratings without permission becomes a breach of the general prohibition

The revenue test looks forward. The FCA asks for projected revenue from providing ESG ratings for the 12 months after the firm submits its application, not last year's figures.

What counts as an ESG rating

The Explanatory Memorandum to the ESG Ratings Order 2025 describes an ESG rating as an assessment of one or more environmental, social or governance factors, prepared using an established methodology and expressed in a defined system of rating categories, such as scores, letters or colours.

The regulated activity is providing such a rating where it is likely to influence a decision to make a specified investment, carried on by way of business. A firm provides a rating when it both produces it and makes it available. A firm that only distributes ratings produced by someone else is not intended to be caught.

The test is whether the rating is likely to be used in an investment decision, not whether the provider knows how each customer uses it. A rating sold to asset managers, asset owners or benchmark administrators will almost always meet it.

Who is in scope

ProviderIn scope?
UK provider, paid ratings to UK or overseas clientsYes
UK provider, ratings given free of chargeYes
Overseas provider, paid ratings reaching UK customers directly or indirectlyYes
Overseas provider, ratings given free of charge to a UK customerNo
Firm that only redistributes another provider's ratingsNot intended to be caught

Overseas providers need particular care. A rating that reaches a UK user through a data platform or a distributor can still bring the overseas provider into scope. Overseas groups will usually need to decide whether to apply from an existing UK entity, set up a new one, or stop offering ratings to UK customers.

The exclusions

The Order excludes ratings that are already covered elsewhere or that are not meant to influence investment decisions. In summary:

  • ratings provided as part of an activity the FCA already regulates, or under another approval or recognised scheme;
  • ratings that are also benchmarks under the UK Benchmarks Regulation;
  • ratings used to produce, or incorporated into, a credit rating under the Credit Rating Agencies Regulation;
  • ratings provided within proxy advisory services;
  • ratings passed between members of the same group and not made available outside it;
  • occasional or unpaid provision by charities, academics and journalists;
  • accreditation and certification schemes whose purpose is not to influence investment decisions; and
  • ratings produced only to meet a legal or regulatory requirement the producer is subject to.

Each exclusion has conditions. A firm relying on one should record its reasoning, product by product, against the Order and the FCA's perimeter guidance in PS26/22.

What the FCA will expect

The regime applies the FCA's baseline rules for authorised firms, plus rules written for ESG ratings providers. The approach draws on the IOSCO recommendations for ESG ratings and data providers and the ICMA Code of Conduct, which many providers already follow voluntarily.

The FCA's preparation guidance asks applicants to assess the changes they need in five areas:

AreaWhat an applicant should be ready to show
TransparencyPublished methodologies, the data sources used and how ratings are reviewed
GovernanceA board and senior management structure that oversees methodology and quality
Systems and controlsDocumented processes for producing, checking and changing ratings
Conflicts of interestHow the firm identifies and manages conflicts, including where it sells other services to rated companies
Stakeholder engagement and complaintsHow rated companies can raise concerns and how complaints are handled

Applicants must also meet the Threshold Conditions, the minimum standards every authorised firm meets on location, resources, suitability and business model. Senior managers will be approved under the Senior Managers and Certification Regime. The FCA's consultation CP26/37 on the next phase of that regime is relevant to which senior management functions an ESG ratings provider will need.

How to prepare

The FCA's own checklist for firms that are not yet authorised is a good working plan:

  1. Confirm whether each product is in scope, and whether any exclusion applies.
  2. Read the final rules in PS26/22 and carry out a gap analysis against current practice.
  3. Choose the legal entity that will apply.
  4. Assess the people, systems and costs needed for authorisation and for ongoing compliance.
  5. Review the Threshold Conditions and the FCA's expectations of applicants.
  6. Map senior management responsibilities under the Senior Managers and Certification Regime.
  7. Book a pre-application meeting from February 2027 if the business model raises questions of scope.

Firms that are already authorised for other activities do not make a fresh application in the same way, but they need to consider how ESG ratings affect their permissions, business model, governance, and systems and controls, and apply to vary their permission where needed.

Applications that fail usually do so for familiar reasons: incomplete business plans, policies that do not describe how the firm actually works, and senior managers who cannot explain their responsibilities. Our guide to why FCA authorisation applications fail sets these out.

What happens if a firm misses its window

The FCA states that submitting an application does not guarantee authorisation, and that a firm applying late may not receive a decision before the regime starts. The Order includes transitional arrangements: a firm that applies within its window and is still awaiting a decision on 29 June 2028 is treated as outside the regime until the FCA decides. A firm without that protection whose application is refused or withdrawn falls into a transitional regime under which it must stop new ESG ratings business once notified, with limited relief for existing contracts.

The practical message is simple. The window is the route to keep operating without interruption, and the first window closes on 29 July 2027.

How we can help

We advise ESG ratings and data providers on whether their products are in scope, prepare FCA applications and the supporting business plan, governance and controls, and support firms through pre-application meetings and the FCA's questions. For firms already authorised, we advise on permission changes. Our wider work for investment firms is set out on the investment firm authorisation page, and the wider FCA agenda for wholesale firms is in our wholesale banking compliance guide.

Official sources

This article provides general information, not legal advice. Whether a product is in scope depends on its features and how it is provided.

This article is general information as at 6 November 2026 and is not legal advice.

Frequently asked questions

When do ESG ratings providers need FCA authorisation?

From 29 June 2028. Applications open on 24 June 2027 in two windows, set by projected ESG ratings revenue for the 12 months after applying.

Which application window applies to my firm?

Firms projecting £500,000 or more of ESG ratings revenue in the 12 months after applying use the first window, 24 June to 29 July 2027. All other firms use the second window, 30 July to 31 August 2027.

Does the regime apply to overseas ESG ratings providers?

Yes, where their ratings reach UK customers directly or indirectly. Ratings an overseas provider gives to a UK customer free of charge are excluded.

Are free ESG ratings in scope?

For UK providers, yes: free ratings are in scope. The free-of-charge exclusion applies only to overseas providers supplying UK customers.

Are credit rating agencies caught by the ESG ratings regime?

Ratings used to produce, or incorporated into, a credit rating under the Credit Rating Agencies Regulation are excluded. Standalone ESG ratings sold by the same group are not automatically excluded.

What if we apply late?

The FCA states that a late applicant may not receive a decision before 29 June 2028. Without a decision, the firm cannot provide ESG ratings in scope of the regime from that date.

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