ESG Regulations in EU and UK

INREV supports the Platform on Sustainable Finance recommendations to improve the EU Taxonomy’s clarity, usability, and ambition but stresses the need for clearer guidance, phased implementation, harmonisation across jurisdictions, and a better understanding of the non-listed real estate investment sector to ensure practical applicability and avoid unintended consequences.

INREV response to the HMT Consultation on the UK Green Taxonomy. INREV believes that if the UK Green Taxonomy be implemented, it should be simplified, interoperable with existing frameworks (especially the EU Taxonomy), and aligned with real estate sector-specific metrics to ensure practicality, reduce reporting burdens, and support sustainable investment while avoiding unnecessary complexity and regulatory divergence.

Download INREV, EPRA and RICS paper presenting a detailed timeline for the implementation of the Energy Performance of Building Directive (EPBD), outlining key milestones, deadlines, and the responsibilities of the European Commission and member states in enforcing and transposing the directive.

INREV response to TNFD consultation on the draft sector guidance supports the LEAP approach, emphasising the importance of sections on nature-related impacts, risks, and mitigation strategies for real estate companies. INREV highlights the importance of clearer metrics, practical examples, and scalable implementation to ease financial and operational burdens, especially for smaller entities.

On 12 June, INREV filed a response to the FCA consultation on Extending the SDR regime to Portfolio Management welcoming the FCA’s work in addressing the risks of greenwashing and increasing transparency in the sale and marketing of sustainability-related products.

INREV’s snapshot on the Corporate Sustainability Reporting Directive (CSRD) provides information on the applicability of the directive and its interplay with other EU ESG policies.

On 23 January, INREV filed a response to the FCA consultation on Guidance on the anti-greenwashing rule welcoming the views expressed by the FCA aiming to protect investors from misleading information

Download INREV’s latest SDR snapshot to learn how the new rules apply to UK asset managers, distributors, retail investors and institutional investors.

On 6 December, INREV filed a response to Commission consultation on SFDR arguing for fund labels that reflect the investment strategy of the product rather than existing concepts used in Articles 8  and 9, which we believe would better accommodate transition strategies.

Download INREV’s position paper on funds’ names using ESG or sustainability-related terms

Download INREV’s position paper on ESAs joint consultation on the review of SFDR Delegated Regulation

Download INREV’s position paper on addressing Greenwashing

INREV with other real estate associations produced a focused response to the FCA’s Discussion paper 23/1 finance for positive sustainable change: governance, incentives and competence in regulated firms

Download INREV’s position paper on SDR and investment labels consultation

INREV updated the list of ESG-related regulations in EU and UK. 

This survey offers insights into how the real estate industry approaches the definition of sustainable investments and their implementation under the Sustainable Finance Disclosure Regulation (SFDR) and/or the EU Taxonomy.

Read the latest IQ blog interviewing Abigail Dean of Nuveen Real Assets and Justin Travlos of Axa IM Alts for their insights on this survey.

On 3 July, INREV filed its response to the joint ESAs consultation on SFDR Delegated Regulation urging the ESAs to recommend the adoption of sector-specific environmental and social metrics for real estate.

INREV and other industry associations developed a position solutions paper for solving challenges arising from SFDR for real estate investments.

INREV published a list of ESG-related regulations in the EU and UK.

INREV and other industry associations proposed principles and real estate specific metrics aiming to facilitate consistency of disclosures across the EU and UK as well as internationally. Title: ESG metrics for real estate proposal under SDR regime.

Download INREV’s latest snapshot on Energy Performance of Buildings Directive to learn more about this important topic.

On 20 February, INREV filed its response to ESMA’s Consultation on Guidelines on funds’ names using ESG or sustainability-related terms. We encourage ESMA to make guidelines optional for real estate funds open only to institutional investors and to accommodate transitions strategies, among other issues. Click here to see the response.

A research paper exploring the implications of SFDR for the non-listed real estate investment industry sheds light on the challenges of complying with SFDR and how it may distort investment needed for real carbon reduction.

On 10 January, INREV filed its response to the ESAs call for evidence on better understanding greenwashing. Click here to see the response.

On 12 January, INREV and other industry association filed a joint response to the UK FCA’s consultation paper on SDR and investment labels. This response and accompanying proposed metrics for real estate support the FCA’s aim to provide consistent, transparent and comparable reporting and disclosure for real estate portfolios.

INREV published a snapshot on Sustainability Disclosure Requirements in UK which contains a comparison with the SFDR in EU.

INREV has published its third paper on SFDR to update on the latest regulatory developments, highlighting some of the key requirements for the industry ahead of the upcoming deadlines.

A joint INREV, AREF, BPF, CREFC Europe and IPF briefing where Louisa Chender, head of the Sustainable Finance team at the UK’s FCA discussed the SDR proposals and their implications for real estate.

Aleksandra Njagulj, Global Head of ESG for Real Estate for DWS in London gave an update on the just released Sustainability Disclosure Regulation proposal in the UK and the expected implications for the non-listed real estate investment industry.

Download FCA’s proposals on Sustainability Disclosure Requirements and investment labels.

On 13 April, INREV, together with several other associations, submitted a proposal to the FCA on ESG metrics and on product labels.

Abigail Dean, Global Head of Strategic Insights, Real Estate at Nuveen presented on recent insights from regulators that can inform our industry’s approach to implementing SFDR.

On 11 January, INREV responded to the FCA’s discussion paper on Sustainability Disclosure Requirements and investment labels on several points that best represent the interests of the non-listed real estate industry.

: On 26 November, INREV filed a response to the RICS consultation on Sustainability and ESG in commercial property valuation. We suggested to include a stronger focus on climate risk and its impact on property valuation, implications and disclosure of ESG KPI.

The briefing focused on the current UK consultation on climate-related disclosures presented jointly by INREV, AREF and IPF. The issues raised for managers and investors as well as the associations’ proposed responses to the consultation will be discussed by a panel of experts. 

To help the industry navigate the requirements of the SFDR, we have summarised the key provisions with a specific focus on the obligations that will be effective as per 10 March 2021. To learn more also view the briefing on the SFDR.

On 2 February 2021, INREV filed a response to the European Commission’s consultation on Sustainable Corporate Governance. The response developed by the INREV ESG Committee substantially supports the possible initiative on sustainable corporate governance and encourages the real estate industry to consider the environmental, social, human and economic impact in their business decisions. 

On 17 December, INREV filed its response to the European Commission’s consultation on the Taxonomy Regulation. INREV generally supports the work done by the European Commission on Taxonomy; but encouraged further harmonisation among ESG regulations. Download the response below.

Kate Binedell and Matthew Baker, Partners at Bryan Cave Leighton Paisner in London, who presented an update on recent ESG-related regulatory requirements impacting non-listed real estate investment. They were joined by Abigail Dean, Head of Sustainability, Real Estate at Nuveen in London, who discussed some of the practical issues implementing the new regulations present for fund managers.

On 28 August, INREV filed a response in the ESA consultation on regulatory technical standards related to ESG disclosures pursuant to the Sustainable Finance Disclosures Regulation. The response developed by INREV ESG and Reporting Committees supports ESG disclosures that are workable for the real estate investment industry. 

Download INREV’s snapshot on the recent ESG regulatory and policy initiatives.

On 14 February, INREV filed responses to ESMA consultations on integrating sustainability risks in AIFMD and MIFID II. We encouraged ESMA to consider the INREV Guidelines related to sustainability reporting.