BDO: It’s not easy being green

Written by: BDO Posted: 02/07/2021

Dawn Sealey, BDO GuernseyDawn Sealey, Advisory Senior Manager at BDO Guernsey, looks at the regulatory changes that are having an impact on green finance

Anyone with an interest in green and sustainable finance will not have failed to notice the flurry of regulatory changes and developments in this area recently.

The Guernsey Financial Services Commission recently published the results of its Guernsey Green Fund thematic, along with a Spring Green Consultation Paper. It was pleasing to note that there is a strong appetite for green finance in Guernsey. 

The Commission found no evidence of greenwashing within the current population of Green Funds, although it did identify room for improvement in the approaches taken by administrators monitoring Guernsey Green Funds.

At the time of writing, the Guernsey Green Fund had one set of criteria to which green funds should adhere – the Common Principles for Climate Mitigation Finance Tracking. 

The principles state: “An activity is classified as related to climate change mitigation under the common principles if it promotes efforts to reduce or limit greenhouse gas emissions or enhance greenhouse gas sequestration.” 

The thematic report provides useful clarification for fund administrators that while some funds may choose to meet this objective by measuring carbon emission savings, other measurements may be utilised so long as there is “a demonstrable approach in the underlying assets to mitigate environmental damage and that the fund (or parties to the fund) monitors that approach on an ongoing basis with a clear exit strategy for any assets that do not meet the criteria”.

The day prior to the release of the Commission’s green papers, the Sustainable Finance Disclosure Regulation came into force in the EU. 

The Directive requires alternative investment funds (AIFs) to disclose on their websites, in pre-contractual documentation and in periodic reports, how the product meets any environmental or sustainable objectives, the methodologies it uses to measure those and the extent to which it meets those objectives. 

The technical standards that underpin the Directive have not yet been endorsed but are expected to come into force on 1 January 2022. 

Firms to whom the Directive applies are therefore expected to adopt a best efforts approach to compliance with the Directive and the draft standards. 

The timing and nature of the release of the Directive and the standards could make this a challenging Directive to comply with.

In its Spring Green Consultation Paper, the Guernsey Financial Services Commission fed back on the proposal to adopt the EU Taxonomy for Sustainable Finance as an additional alternative green criterion under the Guernsey Green Fund regime.

At the time of writing, the final form of the Taxonomy had yet to be agreed and the Commission has stated that it will continue to monitor this. 

BL73_BDO_illoUK green taxonomy 

In the meantime, the UK authorities have signalled their intention to introduce their own green taxonomy and it is possible that this may also be a potential candidate for a Green Fund criteria.

Adding to this mix, in November 2020 the UK published a roadmap setting out an indicative path towards mandatory climate-related disclosures across the UK economy, aligned with the recommendations of the Taskforce on Climate related Financial Disclosures. The IFRS has also proposed to create a new global Sustainability Standards Board. 

For Guernsey funds marketed into both the EU and the UK, it remains to be seen whether there will be some crossover in the applicable requirements.

One of the key findings of the Commission’s thematic report was that green investment knowledge and expertise was not widespread within the industry and that local firms will have to ensure that staff are appropriately trained, especially with the ongoing oversight obligations on the administrator. 

In addition, firms will need to identify which of the various international standards and regulations may apply to them and their clients and upskill their staff appropriately. 

BDO is well placed to advise firms on their regulatory obligations in respect of Guernsey Green Funds and to provide training. BDO can also provide guidance on a number of different green and sustainable standards. 

• This advertising feature was first published in the May-July 2021 edition of Businesslife magazine

Further information
If you would like to know more, contact:
• Dawn Sealey at
• Steve Desmond at

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