The IPF is not a lobbying organisation. However, it does respond to government and other consultations if they are within the scope of the IPF Mission and the relevant IPF group/committee is of the view that the IPF has something to contribute. Our responses are usually drafted in liaison with other relevant industry organisations, e.g., AREF, BPF, INREV and other members of the European Real Estate Forum, of which the IPF is a founding member. The IPF responses to recent contributions are included below.
February 2025
IPF response to HMT - Green Taxonomy consultation
HM Treasury
January 2025
Submission to FCA and IFRS Foundation Reporting Principles - ESG metrics for Real Estate
This is the latest version of the paper was originally drawn up in April 2022 in response to a request from the FCA for input on best practice principles to inform the development of real estate-specific metrics that enable consistent, transparent, and comparable reporting and disclosure for real estate portfolios and covering all real estate asset classes.
FCA and IFRS Foundation
May 2024
IPF reponse to HMT and to HMRC consultation on draft Co-ownership Contractual Schemes (Tax) Regulations 2024
HM Treasury and HM Revenue & Customs
April 2024
Green Property Alliance letter to DESNZ
Twelve members of the Green Property Alliance, including the IPF, co-signed a letter to the Secretary of State for Energy Security and Net Zero asking the UK Government to publish a full response to its 2021 consultation on minimum energy efficiency standards (MEES) for the non-domestic private rented sector in England. Signatories asked for plans regarding higher standards to be published in order to provide investors and the sector with certainty over the future regulatory framework.
www.propertyindustryalliance.org/green-property-alliance
Department for Energy Security and Net Zero
February 2024
Transparency of land ownership involving trusts
Department for Levelling Up, Housing and Communities
January 2024
IPF response to anti-greenwashing guidance consultation
Financial Conduct Authority
Industry response to Review of Solvency II Reform of the Matching Adjustment
The BPF, AREF, INREV and IPF submitted a joint paper to HM Treasury on the Matching Adjustment in March 2023. This brief submission to the PRA is in response to the consultation paper on the implementation of the conclusions reached after the Solvency II Review.
Prudential Regulation Authority (PRA)
December 2023
Call for Evidence on Commercial Real Estate Statistics
European Commission
IPF response to SFDR Targeted consultation on implementation
The European Commission targeted consultation is aimed at understanding how the Sustainable Finance Disclosures
Regulation (SFDR) has been implemented, any potential shortcomings (including in its interaction with the other parts of
the European framework for sustainable finance), and possible options to improve the framework.
This response was prepared following the discussions of the AREF/BPF/INREV/IPF ESG Working Group.
July 2023
Review of SFDR Delegated Regulation regarding PAI and financial product disclosures
Joint consultation by the European Banking Authority (EBA), European Insurance and Occupational Pensions Authority (EIOPA) and European Securities & Markets Authority (ESMA)
May 2023
Updating and improving the UK regime for asset management
Financial Conduct Authority
Finance for positive sustainable change governance, incentives and competence in regulated firms
Financial Conduct Authority
March 2023
Property industry submission on Solvency II matching adjustment reform
BPF, AREF, INREV and IPF submitted a joint paper to HM Treasury on 23 March ahead of the reform proposals being finalised.
HM Treasury
Levelling-up and Regeneration Bill: reforms to national planning policy
Department for Levelling Up, Housing and Communities
February 2023
VAT treatment - fund management services
HM Treasury & HMRC
January 2023
Sustainability Disclosure Requirements and investment labels
Financial Conduct Authority
December 2022
Proposed changes to UK regulated purpose valuation practice
RICS
November 2022
Broadening the investment opportunities of defined contribution pension schemes
Department for Work and Pensions
September 2022
Analysis of PIF(CS) proposals
HM Treasury
July 2022
ISSB IFRS S1 and S2
IFRS Foundation
Exposure Drafts ISSB IFRS S1 and S2
Review of the Solvency II Consultation
HM Treasury
Review of the Solvency II Consultation
June 2022
Enhancement and Standardization of Climate-Related Disclosures
Securities and Exchange Commission (SEC)
File Number S7-10-22: Enhancement and Standardization of Climate-Related Disclosures
Technical Guidance for the Accounting and Reporting of Financed Emissions from Real Estate Operations
Joint consultation by PCAF, CRREM and GRESB
Public Consultation on Technical Guidance for the Accounting and Reporting of Financed Emissions from Real Estate Operations
May 2022
Facilitating Investment in Illiquid Assets
Department for Work and Pensions
April 2022
Proposals - ESG metrics for Real Estate (IPF joint signatory)
Subsequent to the submissions to the consultation, Enhancing climate-related disclosures by asset managers, life insurers, and FCA regulated pension providers (see January 2022) the FCA invited real estate industry groups to put forward proposals as to how the large UK pension funds and fund managers with real estate investments could meet the requirements of the Task Force on Climate-Related Financial Disclosures (TCFD) guidelines. The industry’s response is set out in this paper, written by AREF, BPF, CREFC Europe, INREV, IPF, Pensions for Purpose, Social Market Foundation and The Good Economy.
January 2022
Climate and investment reporting: setting expectations and empowering savers – consultation on policy, regulations and guidance
Department for Work and Pensions
Sustainability Disclosure Requirements (SDR) and investment labels
Financial Conduct Authority
Enabling investment in productive finance
Department for Work and Pensions
October 2021
Fighting the Use of Shell Entities and Arrangements for Tax Purposes (IPF joint signatory)
European Commission
September 2021
Enhancing climate-related disclosures by asset managers, life insurers & FCA-regulated pension providers
IPF/AREF Appendix: Metrics for Commercial Real Estate – Alignment in response to FCA CP21/17
Financial Conduct Authority
July 2021
Residential property developer tax (RPDT): Consultation on policy design
HM Treasury
June 2021
The Non-Domestic Private Rented Sector Minimum Energy Efficiency Standards Implementation of the EPC B Future Target
Department for Business, Energy & Industrial Strategy (BEIS)
Introducing a Performance-Based Policy Framework in large Commercial and Industrial Buildings in England and Wales
Department for Business, Energy & Industrial Strategy (BEIS)
April 2021
Review of the UK funds regime
HM Treasury
February 2021
Tax treatment of asset holding companies in alternative fund structures (Second-stage consultation)
HM Treasury
January 2021
The Non-domestic private Rented Sector minimum Energy Efficiency Standards. The Future Trajectory to 2030
Department for Business, Energy & Industrial Strategy (BEIS)
Review of EU rules on alternative investment fund managers directive (AIFMD)
EU Financial Stability, Financial Services and Capital Markets Union (FISMA)
December 2020
ISAs and authorised open-ended property funds
HM Treasury
If you feel that the IPF should be responding on any specific consultations - either industry or government - please contact Sue Forster, Chief Executive [email protected].