The 2025 PRI Transparency Reporting season is officially underway. Beginning May 7th, Signatories may begin entering responses into the PRI reporting portal, with final submissions due by July 30th. In advance of this window, the Silver ESG Team has compiled a summary of notable updates, key regulatory developments and strategic considerations to help Signatories navigate the reporting process with confidence and clarity.
What Has Changed in the Framework?
The 2025 Reporting framework remains largely unchanged from 2024, with fewer than twenty total changes. However, several of these updates could influence how Signatories prepare and present their responses, including:
- New ORO Module: The addition of the Other Reporting Obligations (ORO) module has been introduced, which contains two questions on a Signatory’s (i) regulatory; and (ii) voluntary sustainability reporting efforts, outside of the PRI.
- Language Refinements: Significant language changes were made to several existing indicators within the Policy, Governance and Strategy module, which could potentially require a refreshed interpretation or revised answers from Signatories.
- Assessment Adjustments: Other minor changes were made across the framework, including assessment criteria changes to indicators in the Listed Equity, Fixed Income and Hedge Fund modules.
These changes underscore the importance of careful review and planning, particularly for firms with investor or regulatory obligations linked to PRI reporting.
A Fork in the Road: Reporting Options for 2025
Perhaps the most important change to the reporting process this year is the introduction of the “partially mandatory” reporting route. First announced in December 2024, this option allows any Signatory who has previously publicly reported to the Transparency Framework the option to report only on the Senior Leadership Statement and ORO module and forgo other disclosures. Importantly, this route will result in a Signatory not receiving an assessment for 2025 and is not available for Signatories who have not publicly reported previously.
Silver has seen a mixed reaction across our client base and the PRI community at large to the partially mandatory option. Many of our clients have chosen to continue reporting in full, as in previous years, but other Signatories are jumping at the chance to reduce their sustainability disclosure obligations. For more information on the full scope of sustainability regulatory changes, please see our recent roundups for Q1 2025 here and EOY 2024 here.
When deciding on their reporting route for 2025, Signatories should consider side letter obligations related to PRI Reporting, investor expectations, assessment pressures and other factors.
Progression Pathways Update
The Progression Pathways initiative, PRI’s upcoming rework to reporting, has been top of mind for many Signatories. On April 23, 2025, the PRI released an update that lays out an example implementation guideline and a preview of how pillars and practices will be structured.
See the graphic below for more information on the pathways:
Source: Pathways in action” by the PRI. To understand more about pathways, pillars and practices visit pathways.unpri.org.
Though not yet live, these pathways are positioned to become an important tool for long-term strategic planning and may soon influence how investors and stakeholders evaluate PRI participation. Silver expects more meaningful updates on Progression Pathways in the 2nd half of 2025, after this year’s Transparency Reporting window has closed.
PRI in the Spotlight: Noteworthy Mentions in the News Cycle
Recent legal and political developments continue to place signatory organizations, such as the PRI, under scrutiny in broader debates around ESG. While these headlines are often driven by anti-ESG sentiment, they contain important takeaways for Signatories, especially those navigating regulatory uncertainty in the United States. Importantly, Silver has not yet observed significant, concentrated pushback against PRI Signatory status.
Below, the Silver ESG Team summarizes each instance, the implication for PRI and our guidance:
- Tennessee v. BlackRock – In December 2023, the Tennessee Attorney General sued BlackRock on the basis that the manager had violated the state’s Consumer Protection Act. The suit claimed that BlackRock had misled its clients about the role of ESG factors in the company’s management of its mutual funds and other investments. The Attorney General suggested in the lawsuit that PRI commitments and other ESG alliances might create conflicts of interest if ESG policies take precedence over financial returns. In January 2025, the case was settled; one notable stipulation requires BlackRock to publicly disclose its PRI signatory status, among its memberships in other “Climate-focused Organizations” on its website.
Silver’s Guidance: PRI Signatories should confirm: (i) their Signatory status is not evaluated or prioritized as part of the firm’s investment decision making; (ii) references to their status as a PRI Signatory is clear in relevant disclosures and marketing materials; and (iii) the firm’s name is appropriately listed on its public PRI Signatory page.
- American Airlines ERISA ESG Case – Plaintiffs argued that American Airlines failed to monitor BlackRock’s proxy voting activities in its role as the company’s 401(k) plan manager. Additionally, the suit claimed that ESG priorities at American Airlines conflicted with its fiduciary duty to beneficiaries. The courts sided with plaintiffs, with a federal judge ruling that American Airlines “turned a blind eye to BlackRock’s ESG activism.” Importantly, American Airlines has appealed the initial ruling and Silver expects further activity on this case throughout 2025.
The PRI is mentioned twice in the findings of the case: first, to establish the fact that BlackRock is a PRI Signatory; and second, to show that the pool of managers that American Airlines considered to manage its 401(k) plan assets consisted almost entirely of PRI Signatories.
Silver’s Guidance: Becoming a PRI Signatory has three main requirements: (i) maintaining a responsible investment policy (or similar) that is applicable to 50% of the Signatory’s assets; (ii) demonstrating senior level oversight of the policy and mechanism for implementing the policy; and (iii) appointing a person(s) to be responsible for implementation. PRI Signatories are not required to prioritize or consider their Signatory status in investment decision making. Becoming or remaining a PRI Signatory does not require that an investment manager or asset owner have or launch an ESG fund or similar, thematic product. PRI Signatories should be aware of these requirements and their disclosure obligations and should not misrepresent the impact of this status on investment decision making.
- House Judiciary Report on ESG Collusion – A 2024 congressional report by Republican House Judiciary Committee members reports that there is evidence a “climate cartel” has colluded to force American companies to “decarbonize” and reach “net zero”.
PRI is mentioned various times in this report. First, PRI is named as one of the bodies that participated in the formation of ClimateAction100+ (CA100+). Next, the Report quotes three of PRI’s six principles of responsible investment. And finally, it quotes a PRI publication that represents’ PRI’s view of the aviation and climate change.
Silver’s Guidance: Signatories of PRI are not automatically members of CA100+. Membership in CA100+ must be undertaken directly and separately. PRI’s six principles of responsible investment are sector and industry agnostic and are qualified as aspirational. PRI publishes its general views on various topics, which are intended to be useful and informative to its Signatory base and relevant at the time of publication. PRI Signatories should be aware of their memberships with collaborative organizations and any underlying commitments, including their aspirational nature. When relying on publications from PRI or other collaborative organizations, always seek to fact check and verify the information being relied on, either directly or via a third-party.
Final Thoughts
While certain headline news and general anti-ESG sentiment may create a false sense of alarm for PRI Signatories, in our view, the PRI and its Signatories are relatively insulated from more discrete pushback from anti-ESG actors due to the broad nature of the PRI’s mission and the minimal requirements to establish and maintain Signatory status. However, voluntary participation in certain PRI-backed activities, such as CA100+ or other collaborative engagement efforts, may open Signatories to greater risk from the anti-ESG contingent. We urge Signatories to be mindful of their commitments and disclosures on an on-going basis.
Please contact the Silver ESG Team at [email protected] for more information on our PRI Reporting solutions or with any questions on the PRI more broadly.