IFSCA ESG Framework Overview 2025
IFSCA ESG Framework Overview 2025
January 2025
01 IFSCA: Overview
Disclosures by Fund
03 Management Entities for ESG
Schemes
05 Our Team
06 Credentials
▪ IFSCA issued a detailed framework on Sustainable and Sustainability linked lending by financial institutions.
▪ This framework is applicable to IFSC Banking Units(IBU) and Finance Companies(FC) and Finance Units(FU)operating in the IFSC, undertaking lending activities from
units in IFSC.
▪ To ensure Consistency, Comparability, and Reliability in disclosures concerning ESG schemes to make certain initial and periodic disclosures. The framework prescribed by
IFSCA is principle-based and largely aligned with international best practices.
Frameworks/
Developed by About
Guidelines
• Framework for responsible financing of green projects and activities.
Green Loans
Loan Market Association (LMA) • Provides a set of guidelines for loan origination, documentation, and reporting to ensure alignment
Principles
with the principles of sustainable development.
• Framework for responsible financing that supports the achievement of social outcomes.
Social Loan
Green/Social/S
• Provides guidelines for loan origination, documentation, and reporting to ensure alignment with
Guidance on
Principals
lending
Part A:
Association (ICMA) • Promotes the financing of sustainable development and responsible investment practices through
Principles
Part B:
• Assesses creditworthiness and financial stability CORE 5. Key Performance Indicators (KPI) Selection
(financial history, credit score, income, assets and COMPONENTS • Selection of KPIs to measure the sustainability performance of the
liabilities, and capacity to repay) of potential borrower (sustainability profile, sustainability risk associated with the
borrowers before loan approval, including and loan, and the sector in which the borrower operates).
assesses alignment with SDGs and ESG factors.
• Selected KPIs should be relevant, credible and measurable.
3. Project Selection
The project selection process according to IFSCA's
sustainable lending framework involves evaluating the
6. Project Evaluation
potential projects for their social, environmental and • Involves a systematic assessment of environmental and social risks,
economic impact and selecting projects that align with impacts and opportunities of a proposed project to determine its
the lender's sustainability goals and principles. sustainability.
Sustainability- Sustainability
The Green Loans Social Loan Bond Climate Bond
Linked Bond Linked Loan (SLL)
Principles Principals Principles Standards
Principles Principles
UltraTech Cement Limited
(UltraTech) has today
The Green Bond One of the Indian On Jan 25, the Reserve announced that it has
State-owned REC Ltd has JK Tyre & Industries
Framework of one of the private development Bank of India (RBI) successfully raised US$500
raised USD 500 million received a USD 100 million
Indian multinational finance institution has staged its inaugural million through a
through green dollar bonds sustainability-linked loan
public sector bank is the first obtained the biggest auction of Sovereign sustainability-linked loan with
to support renewable energy from IFC, including USD 70
green loan issued in the social loan in history, a Green Bonds (SGrBs) with a participation from six banks.
projects. The 5-year bonds million for subsidiary
Indian market for an Indian $1.1 billion facility total value of Rs 8,000 The transaction marks the
have a coupon rate of 4.75% Cavendish Industries
bank. This loan could provide (about Rs 8,700 crore) crore. The centre sold second sustainability-linked
per annum and will mature Limited. The funds will
the basis for additional to finance affordable another 8,000 crore worth of financing raised by
on September 27, 2029. This expand production at plants
green/sustainable housing, highlighting green bonds on Feb 9, thus UltraTech, subsequent to its
marks the first US dollar in Madhya Pradesh and
transactions with the Indian the potential for successfully inaugural sustainability-
bond issuance by an Indian Uttarakhand, promoting
multinational public sector financing that is completing the Rs 16,000 linked bond issuance in
public sector enterprise in energy-efficient tyre
bank and connected to crore in green bond 2021. This financing signifies
2025 production and creating jobs.
other financial institutions. sustainability. issuances planned for the UltraTech’s ongoing
current FY. commitment to align its
funding strategy with its
sustainability and ESG goals.
• Generation of electricity from Renewable Energy (RE) sources such as wind (onshore & offshore), solar, waste to energy, geothermal
energy or production of biofuels from waste sources.
Renewable Energy • Development and/or manufacture of renewable energy technologies, including equipment for renewable energy generation and
energy storage.
• Construction/ maintenance/ expansion of RE associated distribution networks.
• Promotion of energy efficiency in industrial and commercial sectors through development, manufacture and/or installation of
Energy Efficiency technologies for increasing operational energy efficiency of utilities and reducing GHG emissions.
• Energy efficiency in residential building, agricultural equipment and transportation
• Projects addressing reduction of pollution and waste ( e.g. air emissions, greenhouse gas control, soil remediation, waste prevention,
Pollution Prevention and Control
waste reduction, waste recycling and energy/ emission efficient, waste to energy etc.)
• Programs encouraging sustainable land use and sustainable agriculture, including climate smart agriculture which take into
• account climate mitigation and adaptation measures.
Environmentally Sustainable
• Projects that promote a low carbon economy around sustainable agriculture and food security;
Management of Living Natural
• Rehabilitation of sensitive and degraded ecosystems through sound management practices and land use planning.
Resources and Land use
• Projects that promote climate smart animal husbandry, sustainable aquaculture and fisheries, sustainable management of natural
resources and land use products, services and technologies.
Terrestrial and Aquatic Biodiversity • Conservation and enrichment of carbon pools in natural ecosystems.
Conservation • Programs that encourage environmental conservation and sustainable use of natural resources
• Technology to replace or reduce the direct use of fossil fuels, which generate GHG.
• Development of an effective, efficient, integrated affordable and eco friendly public transportation system.
Clean Transportation • Programs encouraging land use planning which allows movement by cycling, walking and public transport.
• R&D programs focusing alternative green fuel.
• Incorporating green technology in transportation infrastructure.
Eco efficient and/or circular • Projects which focus on development of environmentally sustainable products, with an eco label or environmental certification and/or
economy adapted products, resource efficient packaging and distribution.
production technologies and • Production technologies and processes may relate to design and introduction of reusable, recyclable and refurbished materials,
Processes components, circular tools and services.
Employment generation, and • Financing microfinance institutions and financing of SMEs that are often unable to gain access to financial products and Services
programs designed to prevent ✓ Rural populations focusing on agricultural production and agricultural value chains
and/or alleviate Unemployment ✓ Small businesses that demonstrate gender equality at the board and/or ownership level
stemming from socio economic ✓ Provision of financing to businesses run by economically excluded individuals
crises • Financial inclusion through ease of access to financial services and promoting financial literacy.
• Access to health, education, vocational training, healthcare, financing and financial services e g ramping up of health and
• wellness centers in rural and urban areas)
• Infrastructure for the provision of emergency medical response and disease control services.
Access to Essential Services • Supporting health care related products and services such as provision/ distribution of healthcare equipment and R&D and
• manufacturing for equipment for the provision of emergency medical response and disease control services.
• Construction of public schools
• Training for educational professionals that is accessible to the public/ low income individuals
Affordable Housing • Access to adequate, safe and affordable housing for excluded and/or marginalized populations
• Physical social and economic access to safe, nutritious and sufficient food, that meets the dietary needs and requirements.
Food Security and Sustainable • Resilient agricultural practices
Food Systems • Reduction of food loss and waste
• Improved productivity of small-scale producers
▪ Regulatory Basis: Issued by IFSCA under the IFSCA Act, 2019, and Fund Management Regulations, 2022.
▪ Purpose: Ensure consistency, comparability, and reliability in ESG scheme disclosures in IFSC, establish standards and practices for FMEs launching and managing ESG
schemes, and align with international best practices
▪ Applicability: Applies to FMEs launching ESG schemes, including retail schemes, ETFs, restricted schemes, and venture capital schemes.
▪ Criteria: Schemes with terms like ‘Environment’, ‘Social’, ‘ESG’, ‘Green’, ‘Sustainability’, or marketed as ESG-focused.
2) For every ESG scheme launched by a FME, the following disclosures shall be suitably made in the Offer Document / Placement Memorandum, as the case may be:
In order to enable investors to discern the ESG characteristics / themes / intended outcomes of an ESG
A Name of the Scheme scheme, the name of an ESG scheme should be reflective of its ESG focus and consistent with its ESG-
related investment objectives and investment strategy.
FME should transparently disclose the nature and extent of the scheme’s ESG-related investment objectives,
B Investment objectives
including details of the primary components of sustainability addressed by the scheme.
The disclosures relating to this section should consist of a detailed explanation of the type of investment
C Investment strategy strategy, including the ESG-related investment strategy, that the FME intends to pursue with a view to
achieve the stated investment objectives of the ESG scheme.
FME shall disclose the methodology for processes deemed relevant for ESG investments and include a
description of the same in the Offer Document / Placement Memorandum of the ESG scheme, as may be
applicable.
Further in case of ESG schemes which are retail schemes or ETFs, the FME shall ensure that these
ESG investment related
D processes are also publicly disclosed on their website or by other appropriate means.
processes
The strategy and methodology description may include various tools for investment decisions, such as the
investment universe, methodologies for ESG scores/ratings/criteria/profiles/index and their assumptions,
details of external service providers for these ESG metrics, key performance indicators (KPIs) for measuring
ESG performance, the minimum percentage of investable corpus for ESG objectives, and
definitions/standards for classifying assets as green or sustainable.
Consistent with the need to achieve high levels of transparency, the FME managing an ESG scheme should
disclose all the specific risks that arise on account of the scheme’s pursuit of ESG-related investment
objectives, related investment strategies and processes, in addition to all the other material risks faced by the
scheme.
Disclosure of Risks and Risk
E
Management Practices
Further, wherever feasible, the risk management practices should also be disclosed by the FME.
Wherever feasible, FME may designate a reference benchmark for the ESG scheme to measure the
attainment of its ESG focus and/or financial performance vis-à-vis the benchmark.
F Benchmark
Where such a benchmark is designated, the FME should provide explanation as to how it is relevant to the
scheme and also provide a link to the benchmark methodology in the offer document or placement
memorandum of the scheme.
For every ESG scheme launched, FMEs must disclose to the Authority and investors, on
a half-yearly basis for retail schemes and annually for other schemes, compliance with
ESG-related investment objectives, ESG performance, and the actual proportion of
FMEs managing ESG schemes which are in the nature of retail schemes
investable corpus aligned with ESG objectives. If engagement with investee companies is
or ETFs shall publicly disclose the above at a suitable place on their
significant, efforts and voting activities must be disclosed. Additionally, FMEs must
website or by other appropriate means.
compare the scheme's performance with its benchmark, report any changes in
methodologies or processes, update on changes in external ESG score providers, and
share key findings from internal audits or third-party validations.
The FME should undertake, on a half-yearly basis for a retail scheme and on annual
ETFs or Schemes tracking an basis for other types of schemes.
ESG Index shall comply with
the requirements under this • Assessment of their compliance with the stated ESG-related investment objectives
Circular to the extent of the schemes.
Passive Monitoring &
applicable and provide • Measurement of the ESG-related performance of the scheme by evaluating any
ETFs or Performance pre-determined KPIs, expected outcomes and other relevant factors.
complete details of the chosen
Schemes Index, including its Evaluation • The marketing materials and advertisements are consistent with the disclosures
methodology and composition, made in terms of this Circular.
along with the rationale for • Fiduciary Declaration: Authorized person certifies adherence to ESG objectives
choosing the Index. and strategy, potentially backed by third-party validation. Report material
deviations to the Authority.
▪ Role of ESG Debt Securities: ESG-labelled debt securities (Green Bond, Social Bond, Sustainability Bond, Sustainability-linked Bond) are crucial for financing sustainable
development and transitioning to a low-carbon economy.
▪ Global Concerns: Stakeholders, including investors, are increasingly concerned about the accuracy and reliability of sustainability claims by issuers.
▪ Greenwashing Definition: Greenwashing involves making unsubstantiated, false, vague, exaggerated, or misleading claims about sustainability benefits, and includes
concealing or omitting relevant information and emphasizing positive environmental aspects while downplaying harmful attributes.
IFSCA (Listing) Regulations, 2025 requires one of the following international In November 2022, the International Organization of Securities
standards/principles to be adhered to in order to label the debt securities as Commissions (IOSCO) published a paper on “IOSCO Good
Sustainable Finance Practices.” The paper highlights good
“green”, “social”, “sustainability” and “sustainability-linked” bond: practices for product-level disclosures, including naming,
labelling, classification of sustainability-related products,
investment objectives, strategies disclosure, and monitoring
compliance and performance.
An issuer of debt security in IFSC shall not use the name “Green”, “Social”, “Sustainability”, “Sustainability-linked”
or similar terms or a combination of these terms in the issuance of ESG labelled debt securities or its marketing,
Being True to Label - Avoid misleading
A unless the securities are aligned with any of the frameworks recognised by IFSCA. Additionally, the offer
labels and terminology
document and marketing materials, if any must clearly explain how the issue including use of proceeds aligns
with the chosen framework and the specific environmental or social objectives it aims to achieve.
The issuer shall disclose in the offer document a statement on ESG objectives, details of process followed for
evaluating and selecting the project(s) and/or asset(s), proposed use of the proceeds and details of the systems
Screen the Green - Transparency in
and procedures for tracking the deployment of the proceeds as per the regulation 77 (1) of the Listing
B methodology for project selection and
Regulations, for the issue of securities. The issuer shall avoid the use of broad or generic statements to describe
evaluation
investment screening criteria. Further, disclosures should enable investors to fully understand the product's
sustainability-related investment screening criteria.
The issuer shall outline procedures for ensuring funds are directed solely towards projects or activities as defined
Walk the talk - Managing and tracking in the offer document and also disclose the internal control for managing and tracking the use of proceeds.
C
use of proceeds Details of the systems and procedures to be employed for tracking the deployment of the proceeds of the issue
must be disclosed by the issuer in the offer document.
Overall Impact - Quantification of The issuer shall quantify the negative externalities associated with ESG debt utilization. This could include
D
Negative Externalities metrics for residual environmental impacts or potential environmental risks associated with the financed projects.
Issuers of green debt securities shall continuously monitor and disclose the environmental impact of their projects
financed by the issuance. This includes metrics demonstrating a reduction in adverse environmental impacts
E Be alert - Monitoring and Disclose
(e.g., carbon emissions, pollution levels) and progress towards a sustainable economy, as outlined in the offer
document.
• While the above principles may not be exhaustive, Issuers may adopt additional methods, disclosures, and processes to assure investors
against greenwashing.
• Stock exchanges in IFSC where the ESG labelled debt securities are listed / intended to be listed shall monitor the initial and ongoing
disclosures and where warranted, seek necessary clarifications from issuers. Any case of potential or actual greenwashing shall be
analysed and shall be brought to the attention of IFSCA with comments.
• IFSCA will take suitable action under the IFSCA Act, 2019, and Listing Regulations in case of greenwashing incidents.
Vinesh Nayaka
Assistant Manager
Mayukh Das, Debraj Datta and Shobhit
Bhatnagar also preside as Associate
Directors of our team, bringing great value Mridul Bagga
and specialized expertise with transformative Assistant Manager
insight and knowledge.