12 Jan 2024

Following the publication of the FCA’s Policy Statement (PS 23/16) on FCA - Sustainability Disclosure Requirements (SDR) and investment labels , the paper on ESG Metrics for Real Estate has been updated accordingly in January 2024.

ESG Metrics for Real Estate - Proposals 12 January 2024

The proposals contained in this document represent the views of a working group (‘Working Group’) of representatives from AREF and six other associations1  (‘Associations’)

The paper was originally drawn up in April 2022 (The original and other updates to the paper can be found below2) in response to a request from the FCA for input on the development of real estate-specific metrics.

The main aim of the paper is to set best practice principles:

  • to inform the development of real estate-specific metrics that enable consistent, transparent, and comparable reporting and disclosure for real estate portfolios and covering all real estate asset classes (committed via equity and/or debt); and
  • that are aligned with TCFD guidelines (and intended to supplement the PRI - Technical Guide: TCFD for real asset investors) and PS23/16.

The principles and real estate specific metrics aim to facilitate consistency of disclosures across the UK as well as internationally where the TCFD’s recommendations will apply. While the principles are aimed at supporting consistent reporting and disclosure by international asset managers, local supplements may be appropriate or needed for domestic real estate-specific metrics. In the context of realising this aim, the Working Group looks forward to progressing their dialogue with the FCA.

Organisations will not be able to report on all of these metrics from day one nor are these proposed as a set of criteria for the four sustainability investment labels under PS23/16. Therefore, the Working Group puts forward these principles and suggested metrics on the basis that they are not mandatory but voluntary metrics that provide investment and asset managers, and other industry stakeholders with freely available, material, and comparable real estate specific metrics that support consistent and transparent disclosure.

As policy - alongside technological advances and industry ambitions for ESG performance – evolves, ESG metrics for real estate will need to be updated, and (as appropriate) the FCA regulations from time to time revised to reflect the updates.

The updated paper has been shared with the FCA, the International Sustainability Standards Board (ISSB) and the Secretariat to the UK Transition Plan Taskforce (TPT). The TPT have recently been consulting on its sector-specific guidance for preparers and users of climate transition plans, including Asset Managers and Asset Owners.

AREF has provided an overview of the paper to members of the  Alliance of International Fund Associations (AIFA). Also, AREF has shown its support for the paper in response to:

If you would like to contribute to the ongoing dialogue on ESG metrics for real estate please contact Jacqui Bungay ([email protected]), Policy Secretariat, AREF.


1 Associations involved in drafting the ESG Metrics for Real Estate paper:  

Association of Real Estate Funds (AREF)

British Property Federation (BPF)

Commercial Real Estate Finance Council Europe (CREFC Europe)

European Association for Investors in Non-Listed Real Estate (INREV)

Investment Property Forum (IPF)

Pensions for Purpose (PfP)

The Good Economy (TGE)


Previous versions of the ESG Metrics for Real Estate paper:

ESG Metrics for Real Estate - Proposals 13 January 2023

ESG Metrics for Real Estate - Proposals 13 April 2022



Jacqui Bungay

Jacqui Bungay

Head of Policy and Company Secretary, AREF

Jacqui is AREF’s Company Secretary and provides policy guidance and secretariat services to AREF’s Board and Management Committee as well as many of AREF's committees and working groups.

Jacqui joined AREF in 2014 after working for over 25 years in fund compliance, client relationships and administration in the trustee and depositary sector.