ARTICLE
17 February 2026

ICLG – Environmental, Social & Governance Law 2026

D
Dechert

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The role of sustainability in the operations and investment management activities of asset managers has long been a subject of discussion and, in some jurisdictions, controversy.
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The role of sustainability in the operations and investment management activities of asset managers has long been a subject of discussion and, in some jurisdictions, controversy. In recent years, however, the conversation among some investors has become more urgent and focused, driven by concerns aboutthe impact of climate change.

At the same time, the conversations relating to sustainability and ESG have become much more political and nuanced, particularly in the US.

These conversations and controversies, which reflect differing attitudes on sustainability and its role in asset management, willlikely continue for the foreseeable future. For global asset managers, it is increasingly difficult to navigate the differing regulatory approaches to, and investor views on, sustainability in the jurisdictions in which they seek to offer and manage investment products. These challenges will likely continue.

In this chapter, we will discuss the primary regulatory framework relating to sustainable finance and ESG in several key jurisdictions, namely the EU, the United Kingdom (UK), Hong Kong, Singapore and the US.

The authors gratefully acknowledge the contributions of Julien Bourgeois and Olivia Sedita to this chapter.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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