26 October 2021

ESAs re-issue SFDR product disclosures

6-month climate objectives delay now ‘likely’, as ESAs re-issue SFDR product disclosures;

On Friday evening, the European Supervisory Authorities (ESAs) published their finalised set of Sustainable Finance product disclosure (SFDR) specifications.

These are now expanded to incorporate additional Taxonomy regulation (TR) requirements in an attempt to create a ‘single ESG rulebook’ for financial market participants.

The ESAs have decided to modify their previous SFDR Product disclosure rules, covering:

  • Article 8 products (i.e. promoting environmental or social characteristics)
  • Article 9 products (i.e. directly pursuing sustainability objectives).

Ongoing, additional factors will be applied for both product types in relation to their specific environmental objectives (i.e. as obliged by the TR). These will determine the overall disclosure levels required for each UCITS / AIF (i.e. as illustrated in the ESA’s revised pre-contractual and periodic statements templates).

The first two TR environmental objectives relate to climate change mitigation and climate change adaptation, currently scheduled to commence from 1 January 2022.

However, the ESA’s now consider it ‘likely’ that the European Commission will adopt all required ESG disclosure rules in one single delegated regulation, expected to apply from 1 July 2022.


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