Stakeholder Letter - Feedback from the Consultation Paper on Sustainability-Related Investment Disclosures (2026-04-01)

Summary

This is a stakeholder feedback letter from the Bermuda Monetary Authority summarising responses to its September 2025 Consultation Paper on introducing sustainability-related disclosure requirements for investment funds and prohibiting misleading fund names. It explains how the BMA is revising its proposals in response to industry comments and sets out expected next steps before the changes become binding law.

• Definitions: The BMA is reviewing and narrowing the proposed definitions of sustainable investing and sustainable factors, and has dropped the standalone definition of sustainability, to avoid capturing funds that consider ESG factors incidentally rather than as a specified objective.
• Disclosure approach: Prescriptive disclosure requirements will be replaced with principles based, outcomes focused requirements proportionate to how central sustainability is to a fund's objective or strategy.
• Content of disclosures: Where a fund claims a sustainable investment objective or strategy, its offering document is expected to clearly explain how sustainability factors feature in the investment objective/strategy and decision making, related material risks or limitations, and the basis for any sustainability related targets, benchmarks or metrics used.
• Feeder funds: Bermuda feeder funds remain within scope even where the overseas master fund is subject to another sustainability disclosure regime (e.g. EU SFDR); reliance on that overseas compliance may be permitted, but the Bermuda feeder fund's own offering document disclosures must still be fair, clear and accurate.
• Fund names: The prohibition on misleading fund names is unchanged from the original consultation; authorised and registered funds must ensure their names do not misrepresent their investment activities or objectives.
• Implementation timing: Once the amendments are incorporated into applicable legislation, registrants are anticipated to have 6 months to come into compliance.

No new binding rules take effect through this letter itself; it is a feedback and status update ahead of formal legislative amendments. Stakeholders with questions are directed to contact the Authority at policy@bma.bm.

Key obligations

• Once the proposed amendments are incorporated into legislation, funds claiming a sustainable investment objective or strategy must ensure offering document disclosures are fair, clear and sufficient to explain the role of sustainability factors, associated risks/limitations, and the basis for any related targets or metrics used
• Registrants will have 6 months from incorporation of the amendments into legislation to achieve compliance
• Authorised and registered funds must ensure fund names do not misrepresent the fund's investment activities or investment objective
• Bermuda feeder funds remain within scope of the sustainability disclosure requirements and must ensure their own offering document disclosures are fair, clear and accurate even if relying on an overseas master fund's compliance with another ESG disclosure regime

Applies to

investment funds, authorised and registered funds, Bermuda feeder funds, fund registrants

Deadlines

• 6 months after amendments incorporated into applicable legislation: Anticipated compliance period for registrants once the sustainability disclosure and fund name amendments are formally incorporated into legislation