Shai began his career on the buyside at what is now JP Morgan AM, before moving to the sellside where he worked in several research roles. He was Head of Research at Macquarie Group for 10 years before founding Integrum ESG in 2018. Shai has an M.A. in English from Cambridge University.
With the forthcoming introduction of new ESG ratings regulations in the European Union and the United Kingdom many firms are assessing whether distributing third-party ESG ratings could bring them within scope of the new regulations.
This article addresses the question of whether distributing ESG ratings issued by a third-party provider (such as Integrum ESG) will cause the distributor to be captured by the new EU or UK ESG ratings regulatory regimes.
The short answer is no. Distributing third-party ESG ratings without modification does not in itself trigger the application of the new ESG ratings regulations in either the EU or the UK.
The EU ESG Ratings Regulation Regulation (EU) 2024/3005 will apply from July 2026. The UK regime currently set out in FCA Consultation Paper CP25/34 is expected to come into force later in June 2028.
Although the UK rules are not yet final the two regimes have been deliberately aligned. The European Securities and Markets Authority and the UK Financial Conduct Authority have sought to ensure consistency between the frameworks, and the UK proposals closely reflect the structure and intent of the EU regulation.
Integrum ESG has participated in discussions with the FCA working group and remains involved in the consultation process.
Under Regulation (EU) 2024/3005 the regulatory obligations apply to ESG ratings providers.
An ESG ratings provider is a firm that ‘issues’ ESG ratings. Firms that merely ‘publish’ or ‘distribute’ ESG ratings issued by a third party are not ESG ratings providers for the purposes of the regulation.
Articles 2(1) and 3(4) of the regulation make this distinction explicit. Issuing an ESG rating is a regulated activity. Publishing or distributing a third-party ESG rating without modification is not.
As a result:
Integrum ESG, as an issuer of ESG ratings, will fall within scope of the regulation and is expected to be classified as a ‘Small ESG Ratings Provider’.
Firms that distribute ESG ratings issued by Integrum ESG or by other third-party providers will not be captured provided they do not modify the ratings and do not present the ratings as their own.
Distribution alone does not meet the legal definition of issuing an ESG rating under the EU framework.
The proposed UK ESG ratings regime adopts the same approach to regulatory scope as the EU regime.
The FCA consultation paper draws a clear distinction between ESG ratings providers and distributors of third-party ESG ratings. Only firms that produce or issue ESG ratings are intended to be regulated as providers.
Firms that distribute ESG ratings issued by a third party without altering them fall outside the regulatory perimeter.
Following a change from the initial proposal, the new proposal in the Consultation Paper CP25/34 makes clear that distributing third-party ESG ratings without modification should not bring a firm within scope of the proposed UK ESG ratings regime.
Both the EU and UK frameworks also contain explicit exclusions for ESG ratings that are used within regulated financial products or services.
Article 2(2) of Regulation (EU) 2024/3005 excludes ESG ratings where they are incorporated into products or services that are already subject to EU financial services regulation. The perimeter text of the UK proposals includes a corresponding ‘Regulated products and services exclusion’.
Where third-party ESG ratings are used within regulated financial products or services, those activities are not expected to be subject to the new ESG ratings regimes even if they might otherwise fall within scope.
Distributing ESG ratings that are issued by a third-party provider such as Integrum ESG does not in itself trigger the application of the new EU or UK ESG ratings regulations.
In both jurisdictions the regulatory focus is on firms that issue ESG ratings. Firms that distribute third-party ESG ratings without modification and without presenting those ratings as their own are not intended to be regulated under the new regimes.
Moreover, while ESG ratings providers will be subject to authorisation and ongoing obligations, firms acting solely as distributors of third-party ESG ratings, particularly where those ratings are used within already regulated financial products or services, would not be captured.
Updated as at January 2026. UK ESG ratings regulation remains subject to consultation and finalisation.
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