Investor Reporting Framework

Why are signatories asked to provide a breakdown of their investments by asset class?

We continue to ask signatories for a breakdown of their investments by asset class and strategy (where relevant), as this enables the online Reporting Tool to determine which reporting modules and indicators are relevant and material for each individual signatory. 

How should signatories report on fund-of-fund investments?

Fund-of-fund investments should be reported as externally managed assets in the Organisational Overview (OO) module and reported on within the Selection, Appointment and Monitoring (SAM) module.

How should signatories report on multi-asset investments?

As the Reporting Framework asks for the asset class breakdown of total AUM, signatories should split multi-asset investments into the respective asset classes, based on their best estimate.   

For example, if a fund consists of 50% listed equity and 50% fixed income and accounts for 10% of a signatory’s total AUM, it should be reported as 5% listed equity and 5% fixed income.

How will indicator response prefilling work in 2024? 

If your organisation completed reporting in 2023, you will automatically see your previous responses prefilled in the Reporting Tool and highlighted in an amber box.  

Signatories will need to check and confirm each prefilled answer for accuracy in the tool, by clicking save, or save and continue, before submitting their 2024 reports and will be able to make amendments to their answers where necessary.  

We encourage signatories to start preparing offline before the reporting window opens in May, using their 2023 Transparency Reports and the Indicator Changes Guide to identify where they might need to amend their prefilled answers or where indicators will not be prefilled. 

How does the PRI tailor the Reporting Framework for different types of investors?

The Reporting Framework is practice and activity relevant. Therefore, when reporting, only the relevant asset class-specific modules and indicators will be unlocked and assessed in the Reporting Tool, depending on the AUM distribution and practices of each signatory.

Can asset owners choose to voluntarily report on their internally managed assets through the asset class modules?      

The full asset class modules, including all indicators (questions), continue to be available for all signatories on the PRI website. However, asset owners cannot report to the PRI on the asset class modules, nor does the PRI provide feedback and assessment on those modules for asset owners.    

The PRI decided to remove reporting on the direct asset class modules for internally managed assets in response to previous signatory feedback to streamline the reporting experience for asset owners.  

This resulted in us restructuring elements of certain modules, such as Organisational Overview (OO) and Policy, Governance and Strategy (PGS), removing the option for asset owners to voluntarily report on their internally managed assets through the asset class modules.    

As in previous years, where asset owners outsource their investment activities to external investment managers and have chosen to report, they will be required to report on their selection, appointment, and monitoring of managers in the Selection, Appointment and Monitoring (SAM) module.  

Why is stewardship or active ownership integrated in the Policy, Governance and Strategy (PGS) module? 

We believe that stewardship good practice is conducted for two main objectives: (1) to manage ESG risks and opportunities, including at the portfolio level to address systematic sustainability issues that may go beyond individual holdings, and/or (2) to take action on sustainability outcomes. Stewardship can be practiced across many asset classes and is applicable to both asset owners and investment managers.  

The 2024 Reporting Framework structure reflects this, by including questions about stewardship usage - including (proxy) voting, where applicable - in the PGS module, and separately asking signatories to describe how they use stewardship tools to meet their sustainability outcomes targets in the Sustainability Outcomes (SO) module.  

Some questions about stewardship linked to ESG risks and opportunities are process oriented. However, in other questions we expect the leading answers will focus on the use of stewardship to address systematic sustainability issues and/or take action on outcomes, in line with the PRI’s Active Ownership 2.0 framework. 

Are TCFD-aligned indicators considered ‘core’ or ‘plus’?

TCFD-aligned indicators were introduced on a voluntary basis in 2018 and subsequently became mandatory. Reflecting the widespread adoption of TCFD reporting in the industry, in the 2024 Reporting Framework all TCFD-aligned indicators in the PGS module are ‘core’ and therefore mandatory to report on.

Why did the PRI decide to gather several themes in the Policy, Governance and Strategy (PGS) module instead of dispersing them throughout asset-class specific modules?

To reduce repetition across asset modules, we analysed the key themes that would be applicable to most asset classes and collected them in the PGS module. However, signatories can still indicate activities that differ by asset class, where relevant.

What are the minimum requirements for investor membership in the 2024 Reporting Framework? 

The minimum requirements for investor membership in 2024 will be the same as those in 2023. Read more about the minimum requirements. 

What types of questions on sustainability outcomes are included in the Reporting Framework?

There are a few ‘core’ indicators on sustainability outcomes in the 2024 Reporting Framework. These indicators are process-oriented, assessed and, by default, disclosed. They are aligned with two sections of the PRI paper Investing with SDG outcomes: a five-part framework. 

• Part 1: Identify sustainability outcomes 
• Part 2: Set policies on sustainability outcomes 

Any further steps signatories are taking, including measuring and tracking their sustainability outcomes, are included in the Sustainability Outcomes (SO) module.

This module consists only of plus indicators, and therefore is entirely voluntary to report on and disclose. 

Why do signatories automatically get a 1-star score for some reported asset classes? 

In the Organisational Overview (OO) module, we ask signatories if they incorporate ESG issues into their investment decision-making for the asset classes they hold. If a signatory reports that it does not incorporate ESG issues in an asset class, it will automatically be scored 1 star for the corresponding module. This assessment happens regardless of how much AUM is invested in that asset class.  

For more detail on how the information in the OO module affects the reporting process and assessment, please see the Overview and structure guide (PDF). 

Can signatories report having practices and policies in place if they have not yet been implemented but are in the process of developing them? 

Signatories can refer to policies they have established, even if they have not implemented them, but should only report on the practices that they have in place at the end of their indicated 12-month reporting period, which they declare in the Organisational Overview (OO) module. Any practices that were put into place after the indicated 12-month period should be included in later reporting cycles.

When answering questions about general ESG incorporation or stewardship practices, do my answers need to apply to 100% of my organisation’s AUM?

The Reporting Framework contains several questions about general ESG incorporation or stewardship practices, such as OO 8, OO 9 and OO 11 – OO 14. These questions ask whether a signatory conducts these practices in any way, rather than focusing on the level of AUM it applies to a particular practice.

A signatory can answer affirmatively (i.e. yes) that it incorporates ESG factors or conducts stewardship activities, even if the practice only applies to a small proportion of its assets. If it selects ‘yes’, a signatory will then be directed to other indicators where it can specify the extent to which it applies the practice.