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Matthias Knab, Opalesque for New Managers: As ESG regulatory regimes multiply and diverge across the globe, asset managers face a compliance landscape that is becoming harder to navigate from a single playbook. A newly updated global survey by law firm K&L Gates, covering the US, Hong Kong, Japan, Singapore, Australia, the EU, and the UK, maps the state of play as of mid-February 2026 - and identifies the fault lines that will shape fund operations and product development in the year ahead.
The Big Picture: No Common Standard in Sight
The central challenge facing internationally active fund managers is that no two jurisdictions are approaching ESG regulation the same way. Some regions are imposing formal labeling regimes with minimum investment thresholds. Others rely on broad anti-fraud and anti-misrepresentation rules. A few are actively rolling back ESG-friendly policies. The survey authors put it plainly: it is not currently possible to develop a single approach applicable to all jurisdictions. Managers may increasingly need bespoke products built for individual regulatory environments.
That said, one principle is consistent everywhere: regulators expect managers to say what they do and do what they do. Greenwashing enforcement - pursued through very different legal tools depending on the country - is active and intensifying.
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