From January 1, 2026, Regulation (EU) 2025/914 amended the EU Benchmark Regulation (EU BMR) reducing its scope to critical benchmarks, significant benchmarks, certain commodity benchmarks, and EU Climate Transition benchmarks (CTB) and EU Paris-aligned benchmarks (PAB). However, the disclosure requirements under Delegated Regulations ((EU) 2020/1816 and (EU) 2020/1817) that became effective for EU administrators on Dec. 23, 2020, still apply after Jan. 1, 2026, to indices used as benchmarks in the EU that pursue Environmental, Governance and/or Social (ESG) objectives. This document provides answers to frequently asked questions and reflects the regulatory framework as of January 1, 2026.
1. What is the origin and aim of the ESG-specific regulations and requirements?
The ESG disclosure framework stems from the European Commission’s 2018 Action Plan on Financing Sustainable Growth. A key initiative of this plan was to amend the EU BMR to enhance the transparency of ESG benchmark methodologies. The aims of the Delegated Regulations are to:
- Create a common framework of requirements that promotes consistency, leading to greater comparability between benchmarks;
- Clearly state if a benchmark pursues ESG objectives, helping investors to identify them; and
- Generate greater transparency of a benchmark’s objectives to help investors understand them more easily.
2. What are the specific ESG Disclosure requirements?
The Delegated Regulations mandate that benchmark administrators make specific ESG disclosures in two separate documents for benchmarks that pursue ESG objectives: the Methodology and the Benchmark Statement. Additionally, the Delegated Regulations require the use of specific disclosure templates.
- Methodology-Level Disclosures: Administrators of ESG benchmarks are required to use a specific template, to be appended to the Methodology, to disclose information, such as whether the Methodology takes ESG factors into account and, if so, which ESG factors are considered and how. The disclosures also require a description of the sources of ESG input data used by the Methodology, including how the data is verified, how the data quality is ensured, whether the data is provided by internal or external sources, and whether the data is modeled or reported. All index Methodologies are available publicly on the S&P DJI website.
- Benchmark Statement-Level Disclosures: Administrators of ESG benchmarks are also required to append a specific template to each Benchmark Statement with information, such as whether the family of benchmarks governed by the Benchmark Statement take ESG factors into account and if so, which ESG factors are considered and how; whether the family of benchmarks contain any EU Climate Transition Benchmarks (EU CTBs) or EU Paris-Aligned Benchmarks (EU PABs); the disclosure of specified index-level ESG metrics for the benchmark’s asset class; and information on the source of ESG data to provide information on the ESG factors in the Benchmark Statement. All Benchmark Statements and index-level ESG disclosures are available publicly via the S&P DJI website.
- Additional Disclosures for EU Paris-Aligned and Climate Transition Benchmarks: For Benchmark Statements containing any EU PABs and EU CTBs, additional disclosures are required:
- the forward-looking year-on-year decarbonization trajectories;
- the extent to which the benchmarks have achieved the levels of decarbonization required by the minimum standards set for EU CTBs and EU PABs;
- the level of active share for each EU CTB or EU PAB;
- the alignment of the benchmarks with the greenhouse gas emissions reductions and objectives of the Paris Agreement; and
- information regarding the climate models, temperature scenarios, data sets, and methodology used to measure the alignment of the benchmarks with their required decarbonization trajectory.
3. What are "Benchmark Statements" and "index-level ESG metrics"?
- Benchmark Statements:Under the EU BMR, a benchmark administrator is required to publish a Benchmark Statement providing a description of the characteristics of a benchmark or family of benchmarks, along with other information for users required by the regulation.
- Index-Level ESG Metrics: An index-level ESG metric is an indicator calculated to provide an aggregate measure of an index’s performance against a specific ESG criteria (e.g., weighted-average carbon intensity). The metrics are comprised of the characteristics of the index's constituents.
4. Which benchmarks require these ESG Disclosures after Jan. 1, 2026?
While the broader obligations for administrators under the EU BMR have been revised only to the following benchmark classifications: critical benchmarks, significant benchmarks, certain commodity benchmarks, EU CTBs, and EU PABs, the ESG disclosure requirements will continue to apply to all benchmarks used in the EU that pursue ESG objectives.
Note, an administrator’s obligations with respect to a benchmark that pursues ESG objectives are confined to the disclosures (i.e. only the specific ESG disclosure obligations contained in Articles 13(1)(d) and 27(2aa)), unless such benchmark also meets a specific classification (i.e. critical benchmark, significant benchmark, certain commodity benchmarks, EU CTB or an EU PAB).
Please refer to the European Union and U.K. Benchmark Regulation FAQs for more information on the regulated benchmark administrators within S&P DJI and the S&P DJI benchmarks in scope.
In the United Kingdom: The UK BMR continues to apply to all indices used as “benchmarks” in the UK. Therefore, any benchmarks that take account of ESG factors that are administered in the UK must comply with the ESG disclosure requirements.
