“Fund managers marketing products into each of the jurisdictions will be likely be set down a path of differentiated, not harmonised, disclosures.”

[COMMENTARY]A good and detailed analysis and comparison of the different ESG regulations in major global financial jurisdictions.
Comparing ESG disclosure rules for funds in the EU, UK and the US — SFDR, SDR and SEC proposals, by Brent L. Bernel, Rhys Davies, Erin Lachaal, Jesse Medlong, Caroline Pimpaud, Catherine Pogorzelski, Deanna R. Reitman, and Erin Sculthorpe. October 5, 2022, DLA Piper, UK.