The Bermuda Monetary Authority (BMA) has published stakeholder feedback and its response on its September 2025 consultation to add sustainability-related investment disclosures to Bermuda’s investment funds framework and to prohibit misleading fund names. The BMA indicates it will refine key definitions and replace previously proposed prescriptive disclosure items with principles-based, outcomes-focused requirements, while leaving the prohibition on misleading fund names unchanged. Following industry concerns about scope and alignment with international approaches, the BMA has removed the proposed definition of “sustainability” and is reviewing the definitions linked to “sustainable investing” alongside a proposed new definition of “sustainable factors”, aiming to avoid inadvertently bringing funds without a sustainability objective into scope. For offering documents, the BMA will require disclosures to be fair, clear, not misleading and proportionate to how central sustainability factors are to a fund’s objective or strategy, including how such factors are used in investment decisions, any material risks or limitations (including data and methodology constraints), and the basis for any sustainability-related targets, indicators, metrics or benchmarks. Bermuda feeder funds will remain in scope, and where they already comply with other sustainability disclosure regimes such as the European Union’s Sustainable Finance Disclosure Regulations, that compliance may be relied on to demonstrate compliance with the Bermuda framework, provided the feeder fund’s offering document remains fair, clear and accurate. Once the amendments are incorporated into applicable legislation, registrants are expected to have six months to comply.

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