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Climate change litigation update
In the two years since our last climate litigation update, the prevalence and variety of global climate litigation around the world has continued to increase.
United Kingdom | Publication | April 2025
On April 14, 2025, the latest edition of the Financial Services Regulatory Initiatives grid was published by the forum including representatives from the Bank of England, PRA, FCA, Pensions Regulator and Financial Reporting Council, with HM Treasury as an observer member.
The purpose of the grid is to set out details of regulatory initiatives relevant to the financial services sector planned for the next 2 years. The previous edition was published in 2023 and no complete grid appeared in 2024 owing to the general election.
Pensions-related developments include:
Primary legislation required to progress the DB and DC initiatives at the third and fourth bullet points is due to be contained in the forthcoming Pension Schemes Bill, which is due before the summer recess of Parliament. The Regulator is expected to begin work on a superfunds code of practice in early 2026.
Additionally, 12 initiatives contained in the previous version of the grid are now listed in an Annex setting out initiatives either completed or stopped. Items stopped include the Regulator's work on a revised "notifiable events" code of practice. This is the latest indication that the Government and regulators do not intend to progress changes to the notifiable events framework on which the DWP consulted in 2021 following enactment of the Pension Schemes Act 2021.
Also listed as stopped is a regulatory initiative by the Regulator intended to assess compliance with the new climate-related requirements for statement of investment principles and implementation reports by large occupational pension schemes.
Publication
In the two years since our last climate litigation update, the prevalence and variety of global climate litigation around the world has continued to increase.
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