CySEC Circular C752 – ESMA publication of thematic notes on clear, fair & not misleading sustainability-related claims – Second Note: ESG Strategies.

MNK Risk Consulting > Regulatory Developments > CySEC Circular C752 – ESMA publication of thematic notes on clear, fair & not misleading sustainability-related claims – Second Note: ESG Strategies.

Addressed To: Cyprus Investment Fund Managers (including Cyprus UCITS Management Companies and Self-Managed Cyprus UCITS, Cyprus Alternative Investment Fund Managers and Self-Managed Cyprus AIFs, and Sub-Threshold Cyprus Alternative Investment Fund Managers and Self-Managed Cyprus AIFs), as well as Cyprus Investment Firms (CIFs).

CySEC issued Circular C752 on 21 January 2026 to inform the Regulated Entities about the Second Thematic Note on ESG Strategies published by the European Securities and Markets Authority (ESMA) on 14 January 2026, , as part of ESMA’s broader work on ensuring that sustainability-related claims are clear, fair, and not misleading.

This Second Thematic Note primarily addresses ESG Strategies, with a particular focus on ESG Integration and ESG Exclusions.

It is further noted that CySEC previously issued Circular C734 on 14 October 2025 to inform Regulated Entities about ESMA’s First Thematic Note on ESG Credentials.

CySEC encourages Regulated Entities to stay informed about future thematic publications and expects firms to take the guidance outlined in these notes into account when fulfilling their ESG-related regulatory obligations.

* These Thematic Notes issued by ESMA, are relevant  to the guidance issued by CySEC on Sustainable Finance, through circulars C704 and C683 addressed to CyIFMs and CIFs respectively).

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