Responses to Consultations

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.

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]