SFDR Update for Asset Managers, January 2024

January 19, 2024

This update covers December 2023 until mid-January 2024. The main update is that the level 2 text of the Sustainable Finance Disclosure regulation (SFDR RTS) entered into force in Norway on December 11, 2023. Our view on the main takeaways for Swedish and Norwegian AIFMs are set out below.

Consolidated SFDR Q&As 

On January 12, 2024, The European Supervisory Authorities (the ESAs) published an updated version of the consolidated Q&As on the SFDR. 


For the consolidated Q&As, please click here


Permian comment: We have noted very few amendments in relation to the previously issued consolidated Q&As but we of course recommend this latest version. 



Regulatory Technical Standards under the SFDR RTS has entered into force in Norway 

As published by the Norwegian FSA on December 13, 2023, the SFDR RTS entered into force in Norway on December 11, 2023. It is noted that the SFDR itself entered into force in Norway on January 1, 2023. 


For further information, please click here


Permian recommendation: Asset managers should ensure that their SFDR disclosures are compliant with the SFDR RTS. 



Final report on amendments to SFDR RTS  

On December 4, 2023, the ESAs published a final report amending the SFDR. Entry into force is unclear. The ESAs propose, e.g. the following:  


  • Additional mandatory and voluntary social indicators for the principle adverse impact (“PAI”) reporting (including the Do No Significant Harm (DNSH) assessment;  


  • Simplification of the pre-contractual and periodic disclosure templates for financial products; and  


  • Other technical adjustments concerning, among others, the treatment of derivatives, the calculation of sustainable investments, and provisions for financial products with underlying investment options.  

 

For further information, please click here

 

Permian recommendation: Since these are only proposed amendments, no action is currently needed by asset managers. However, we would recommend asset managers launching a new article 9 or 8 fund (that will make sustainable investments) to take the proposed amendments into account to ensure that the fund will be able to fulfill the additional requirements. 

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