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UK leads private market climate disclosures amid regulatory push

by Piyasi Mitra
7 February 2025
UK leads private market climate disclosures amid regulatory push
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Climate disclosures in private markets are gaining momentum, with UK managers leading the way in transparency, according to a report.

The report by Unwritten 360, a climate risk platform covering transition risk, physical risk, nature exposure and carbon, analysed 47 Task Force on Climate-Related Financial Disclosures (TCFD) reports from UK, EU, and US-based general partners (GPs), offering insights into how asset managers are adapting to evolving climate disclosure requirements.

Governance frameworks remain a strong focus, with most UK managers publishing standalone climate disclosures, while EU and US firms typically integrate climate reporting into broader sustainability reports.

“EU and US managers generally include a chapter in a broader sustainability report. This reflects the impact of the Financial Conduct Authority’s TCFD ruling in the UK,” stated the report. However, executive committee endorsements remain low, with fewer than half of UK firms and even fewer in the US and EU including leadership-level commentary in their reports.

Climate risk strategy disclosures have also evolved, according to the report, with half of UK and EU managers identifying specific climate risks—such as carbon taxation or coastal flooding—affecting their portfolios. However, while many managers conduct scenario analyses, only 19% disclose financial impacts for physical risks, and just 11% report financial outcomes for transition risks, suggesting uncertainty in quantifying financial exposures. According to the researchers: “This suggests that managers find financial impact results to be too detailed or insufficiently informative to include.”

26% of European asset managers fail to disclose Waci

The International Sustainability Standards Board guidelines play a key role in shaping climate scenario analyses, with all firms disclosing results including at least three scenarios—one of which aligns with a Below Two Degrees pathway. Meanwhile, risk management remains a focus, with nearly all managers assessing climate risks pre-investment, though US managers lag behind their UK and EU peers in ongoing risk management post-investment.

The report has also highlighted that nearly all managers disclose carbon emissions across Scope 1 (emissions produced directly by company-owned facilities) , Scope 2 (emissions from purchased energy in those
controlled facilities ) and Scope 3 ( emissions attributed to a company’s value chain) , despite ongoing challenges in data collection and methodology. UK and EU managers also led in emissions target-setting, with four in five reporting progress against their targets, compared to just one in ten managers in the US.

Alignment with global net-zero frameworks is increasing, according to the research, with many firms referencing standards like the Private Markets Decarbonisation Roadmap ( PMDR) or Net Zero Investment Framework  (NZIF) 2.0. However, detailed progress reporting remains few, as firms struggle to quantify their alignment and impact in a measurable way.

The PMDR provides a common language that enables Private Equity firms to disclose their assets’ decarbonisation evolution. It recognises firms’ early-stage progress and builds on existing frameworks, giving firms the flexibility they need to decide what and how to disclose. Developed by Bain on behalf of the Initiative Climate International and the Sustainable Markets Initiative’s Private Equity Task Force, PMDR aims to help private equity firms accelerate progress on disclosing and reducing greenhouse gas emissions. The updated NZIF 2.0 offers a comprehensive guide to net zero investing, incorporating three years of experience and input from over 200 investors, streamlining net zero strategy development while helping investors manage climate-related risks and opportunities.

“2025 is the year that ESG teams at General Partners really hone in on delivering positive financial impact through their initiatives. Our report shows that reporting efforts by these teams to date have laid the ground for those ambitious programs of work,” said Alex Spencer, managing director at Unwritten.

The representative sample coverd $4.7tn of US AuM, $1.1tn of EU AuM and $670bn of UK AuM.

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