Minimum requirements for investor membership

Signatory accountability is integral to achieving the PRI’s mission and providing value to our signatories. The minimum requirements for investor membership play an important role within that, ensuring that a baseline level of responsible investment is achieved across our investor signatory base.

Asset owner and investment manager signatories that fail to meet these requirements over a two-year/two-reporting cycle period, following extensive engagement with the PRI, will be submitted to the PRI Board for delisting. 

The minimum requirements

The three minimum requirements that asset owner and investment manager signatories need to meet when reporting on a mandatory basis are listed in the Policy, Governance & Strategy (PGS) module:  

Minimum requirement	Policy, Governance & Strategy (PGS) module indicator	Investment & Stewardship Policy (ISP) module indicator
Reporting year	2024 2023	2021
RI policy, setting out: overall approach to RI or guidelines on E, S, or G factors, and covers >50% of AUM	PGS 1 PGS 8	ISP 1 ISP 1.1 ISP 3
Senior-level oversight of RI	PGS 11	ISP 6
Internal/external staff implementing RI	PGS 12	ISP 7

To view these indicators, download the PGS module, which includes up-to-date explanatory notes and links to supportive resources. 

The main objectives of the minimum requirements are to: 

engage with signatories that have not demonstrated progress in implementing the Principles;
support signatories that are not highly engaged with the PRI to improve their responsible investment practices and demonstrate their commitment to the Principles; and
delist signatories that are not committed to the Principles, as a last resort.

Guidance document for reporting

To help signatories understand what they need to do to meet the minimum requirements, we have produced a guide to the minimum requirements indicators in the Reporting Framework. This provides guidance for signatories to identify and report on those indicators.

Further resources

The following resources are available to help investor signatories learn more about, meet and exceed the minimum requirements: 

Engagement and delisting

The PRI has committed to extensively engage with signatories identified as not meeting the minimum requirements, and to provide them with the support needed to implement necessary changes to meet them within a two-year engagement period. Signatories that do not meet the criteria based on their PRI reporting will be informed privately and delisting will only be a last resort following unsuccessful engagement over the two-year period.

Signatory Accountability Rules

The Signatory Accountability Rules support the integrity of the PRI membership by setting out measures for minimum requirements. Their purpose is to inform signatories of the minimum requirement criteria and the formal process for engagement and delisting. The rules were approved by the Board in December 2017.

Review of the minimum requirements

Our recent signatory consultations and engagements, including the PRI in a Changing World consultation, have highlighted how important signatory accountability is to our mission and the value it brings.

At the same time, changes in the investment reporting landscape and our signatories’ needs and challenges mean that we have to evolve our approach to reporting and ways of ensuring effective and appropriate signatory accountability.

Our minimum requirements remain in place for the 2024 reporting cycle, while we determine the future direction of reporting in tandem with our work in developing the Progression Pathways.

The commitment we made in 2020 to strengthen our accountability mechanisms so that they deliver on our mission and cater to signatories remains but will now take a broader approach to more effectively achieve their purpose.

We look forward to providing more information on this work in the future and are confident that the existing minimum requirements deliver appropriate accountability across our signatory base and remain important considerations for investors in the meantime.

Previous reviews

The PRI’s minimum requirements for investor membership have successfully been driving change since 2018, supporting hundreds of signatories to improve their practices over the two-year engagement period.

In 2020, we began a formal review process, which involved assessing the future applicability of the current requirements, setting out potential new minimum requirements to increase accountability, and reviewing our engagement process and Signatory Accountability Rules.  

PRI sought signatory feedback on the potential changes as part of the 2020 PRI strategy consultation. You can read about the proposed changes to the minimum requirements (PDF). Generally, signatories were supportive of the proposed changes and provided useful feedback for each of the potential new requirements.  

Frequently asked questions

Who the minimum requirements apply to

Do the minimum requirements apply to all signatories?

The minimum requirements apply to asset owner and investment manager signatories only and are reported on through the Investor Reporting Framework.

I am reporting in my grace period – do the requirements apply to me?

Signatories that report in their grace period but do not meet the minimum requirements of membership will be identified and informed, but they will not enter the engagement process.

Do the minimum requirements apply in 2024?

We are taking a more flexible approach to reporting this year and as such, reporting will be voluntary for a larger group of investor signatories. The minimum requirements continue to apply, however, and we will assess the information of all signatories that report in 2024 to identify those that do not meet the minimum requirements.

For those that are not in their grace period, they would then enter the two-year/two-cycle engagement process.

Understanding the minimum requirements

Why were the current three minimum requirements chosen?

When the PRI consulted signatories on strengthening signatory accountability in September 2017, they showed strong signatory support for using reporting and assessment data to delist signatories whose progress in implementing the Principles is not sufficient. View an overview of the consultation responses (PDF).

The current minimum requirements and indicators were selected because they are applicable to all types of signatories. Feedback also indicated that these were achievable within the two-year engagement period and an appropriate place to start for newer and less advanced signatories. The process is intended to help signatories progress through use of PRI resources and networks.

These requirements remain an important first step for investors new to ESG incorporation.

Meeting the minimum requirements

How does the PRI support signatories that do not meet the requirements?

The PRI informs all signatories that do not meet the minimum requirements confidentially. Following this, an engagement plan is agreed for the two-year period and signatories will be supported through the process with the appropriate resources.

How can signatories meet the first minimum requirement – having an investment policy that covers the firm’s responsible investment approach (PGS 1 and PSG 8)?

To meet the policy requirement, signatories must have a responsible investment policy setting out the firm’s overall approach and/or formalised guidelines on environmental, social and governance factors. The policy must cover more than 50% of AUM. Information on how we define a responsible investment policy will be available in the explanatory notes of the indicators in the 2024 Reporting Framework.

How can signatories meet the second minimum requirement – oversight of responsible investment implementation (PGS 11)?

To meet the oversight requirement, signatories must have senior-level oversight and accountability for responsible investment implementation. Individuals with oversight roles are those with management or governance responsibility for ensuring that the organisation implements its policies and achieves its objectives and targets in relation to responsible investment. Senior-level roles include board trustees, executive-level staff, investment committees, heads of department and equivalent.

How can signatories meet the third minimum requirement – responsible investment implementation (PGS 12)?

To meet this requirement, signatories must have at least one person whose role includes responsibility for implementing responsible investment in their organisations – for example, through conducting ESG-related research, incorporating ESG issues into investment strategies, voting shareholdings, and engaging with companies and policy makers. This role can be covered by internal or external staff, does not require dedicated responsible investment/ESG investment staff.

Does our responsible investment policy have to be publicly available?

The first minimum requirement states that signatories must have a responsible investment policy in place, but it does not need to be publicly available. Nonetheless, we recommend that signatories make relevant elements of their policies publicly available to promote transparency, as this is considered to be best practice. Signatories have the option to disclose links to their responsible investment policies when reporting on indicator PGS 3.

Delisting for failure to meet the minimum requirements

Will signatories be delisted if they do not meet the requirements?

Delisting is a last resort if the two-year engagement period is unsuccessful and if the reasons for not meeting them are not deemed to be extenuating. Signatories can appeal the delisting decision.

Are signatories’ fees refunded if they are delisted for not meeting the minimum requirements?

Signatories that are delisted for not meeting the minimum requirements will not have their fees reimbursed. 

Can signatories be relisted after not meeting the minimum requirements?

Signatories that have been delisted and wish to relist will be required to wait one calendar year and then provide evidence that they meet the minimum requirements in place at that time. The grace year will not apply to relisting signatories. These signatories will be required to report in the next reporting cycle.

What happens if signatories revert to not meeting the minimum requirements?

Signatories that revert to not meeting the minimum requirements (including after any relisting) will be required to address the requirements in a one-year timeline. If the requirements have changed in the interim period, the usual two-year period will apply.

Future developments

Will our minimum requirements/accountability work continue beyond 2024?

Signatory accountability is integral to achieving the PRI’s mission and providing value to our signatories.

Our current minimum requirements play an important role, ensuring that a baseline level of responsible investment is achieved across our investor signatory base, and these will remain in place for 2024.

Beyond 2024, we will continue to determine the most effective way to strengthen our accountability mechanisms so that they deliver on our mission and cater to signatories and in parallel to our Progression Pathways co-design work, we will set up a workstream to ensure that we embed accountability mechanisms within these.