Are Investment Advisers in scope of FI guidance?


I represent an Investment Adviser that advises some funds. I’m not sure if the Investment Adviser would be able to submit a target as there is currently no clear guidance for measuring facilitated emissions (different to financed emissions). So although we have calculated the emissions of the funds, we don’t know on what basis to allocate them to the Investment Adviser’s Scope 3 Category 15 Investments.

Please can you advise on whether the current FI guidance is suitable for Investment Advisers, and if so, how should the emissions of the funds they advise be allocated?

The pilot test version 2.0 of the Near-Term Criteria and Recommendations for FIs proposes: Assets managed under discretionary mandates (see Section 5.3 of the Near-Term Financial Sector SBT Guidance for more details) must follow the coverage requirements outlined in Table 1, while assets administered under advisory mandates are optional and assets under custody or execution-only mandates are out of scope.

Depending on the weighting method chosen, emissions data may not necessarily be needed if the Portfolio Coverage and/or Temperature Rating methods are used. Otherwise, they could potentially attribute the portfolio companies’ emissions by taking the amount of the investments being managed as the numerator (and EVIC as the denominator) of the attribution factor.