SFDR Update June - August 2023

August 28, 2023

This update covers the period from June until mid-August 2023. The main update is that the EU Commission published a Sustainable Finance Package on 13 June 2023. Our view on the main takeaways for Swedish and Norwegian AIFMs is listed below.

Implementation timeline for sustainable finance regulations published by ESMA


On 3 August 2023, ESMA published an updated implementation timeline for sustainable finance related regulations. The timeline can be accessed here.


Permian comment: ESMA publishes updated implementation timelines on regular basis. It is an excellent document to obtain an overview of the sustainability related legislations and their entry into force.


Sustainable Finance Package


The Sustainable Finance Package published on 13 June 2023 covers the following five main areas:


  1. Proposal on a new regulation for ESG rating providers: this regulation will apply to service providers of ESG ratings and includes a definition of ESG ratings. It does not apply to service providers of ESG raw data. Its entry into force is subject to the EU legislative process.
  2. Taxonomy delegated acts: the EU Commission adopted the delegated acts that were mentioned in our SFDR Update January – May 2023. Expected entry into force is 1 January 2024.
  3. Transition finance: this recommendation provides information on how companies can use tools from the EU for transition finance. An example provided in the recommendation is that companies can use the Taxonomy by reporting Taxonomy-aligned capital expenditure (i.e. since this would generally provide for a higher alignment in a transition context than reporting Taxonomy-aligned revenue). In addition, the recommendation includes information that could be included in a transition plan.
  4. Clarification on the link between taxonomy-alignment and sustainable investment under the SFDR: according to this notice, investments in taxonomy aligned environmentally sustainable economic activities can be automatically qualified as “sustainable investment” under the SFDR (provided that the taxonomy-alignment relates to the entire company and not only a part of the company’s economic activities).
  5. Staff working document on the Taxonomy: this document includes a summary of the Taxonomy, tools to be used as well as links to other documents related to the Taxonomy.


For further information, please click here.


Permian comment: The package does not include additional reporting obligations on the Manager. For further comments, see below.


  1. ESG ratings: to be followed-up with any ESG rating provider used by the Manager closer to the regulation’s entry into force. (Please note that the definition of ESG rating providers is not fully clear to us.)
  2. Taxonomy delegated acts: to be considered for Taxonomy assessments as of 2024.
  3. Transition finance: to be considered in connection with e.g. preparing a transition plan and for asset managers with a transition finance investment mandate.
  4. Clarification on the link between taxonomy-alignment and sustainable investment under the SFDR: the practical implication of this clarification is that any investment that has been assessed as taxonomy-aligned can also be assumed qualify as a sustainable investment under the SFDR. This should mean that if you disclose that you have taxonomy-aligned investments, then those investments could also be disclosed as sustainable investments in the periodic reporting. Please note however, that if you use this new presumption, then you should first read the clarification since there are some exceptions (such as when a portfolio company’s economic activities have not all been assessed as taxonomy aligned).
  5. Staff working document on the Taxonomy: this document could be read as a summary of the Taxonomy and includes some useful links.

 

Amendment to the Norwegian Regulation under the Sustainable Finance Act


On 13 June 2023, the EEA Committee decided to incorporate Regulation (EU) 2022/1214 into Annex IX of the EEA Agreement. This regulation amends Regulation (EU) 2021/2139, which encompassed a broad range of energy-related activities but lacked technical screening criteria for the fossil gas and nuclear energy sectors, and Regulation (EU) 2021/2178, which fell short in achieving full transparency for these economic activities. With the Amendment Regulation, the fossil gas and nuclear energy activities are now recognized as environmentally sustainable activities with respect to EU’s 6 environmental objectives. The Amendment Regulation has been implemented into Norwegian law in Section 2 of the regulation under the Sustainable Finance Act and came into effect 14 June 2023.


For further information, please click here.


Permian comment: Relevant entities should review how the amendments are applicable to them.



Contacts

 

Anna Berntson Petas: anna.berntson@permian.se


Thomas Blomgren: thomas.blomgren@permian.se


Felicity Guttormsen: felicity.guttormsen@permian.no

December 10, 2025
Permian and Highvern, together with Jacobs Capital, announce the appointment of Caroline Connellan as Group Chief Executive Officer.
Permian's new office at Jakobsbergsgatan 17.
December 9, 2025
To support Permian’s continued growth, its expanding Nordic client base, and its long-term commitment to providing best-in-class fund services, the company has relocated from Vasagatan 36 to new offices at Jakobsbergsgatan 17 in the Mood District. The new premises at Jakobsbergsgatan offer a modern and flexible workplace that accommodates Permian’s nearly 70 employees in Sweden. The office features expanded meeting facilities, improved collaboration areas, and increased workstation capacity to support the company’s continuously growing team and cross-border operations. “Alongside our mission to deliver high-quality services to our clients, our new office gives us room to scale and welcomes focused work as well as innovative and meaningful conversations with partners, clients, and colleagues. A huge thank you to everyone who has been part of this journey so far,” says Johanna Bjenne , Country Head, Sweden. The new office is fully operational. Updated contact details are available on Permian's website under "Contact".
November 19, 2025
As the global fund landscape evolves, cross-jurisdiction collaboration is becoming essential. For the newly combined Highvern and Permian group, that momentum begins with Ireland and the Nordics, where teams are already working together to strengthen onshore fund services and deliver seamless, client-focused solutions across eight jurisdictions: Ireland, Sweden, Norway, Jersey, Guernsey, the UK, South Africa, and the Cayman Islands. Country Heads Emma Keane (Ireland), Johanna Bjenne (Sweden), and Susanne Berge-Hansen (Norway) share insights on how the unified group – now over 300 colleagues with $45bn in assets under administration – is creating value for clients through integrated expertise and a connected, multi-jurisdictional platform. Strength across borders Emma Keane (EK): What makes clients look outside Sweden or Norway when setting up structures in other jurisdictions? Johanna Bjenne (JB): For Swedish managers, it’s a mix of access to capital, tax considerations and investor comfort. Many institutional investors are used to Ireland or Luxembourg structures, so being able to offer that option through the same group helps facilitate a seamless solution. It’s not just a tax discussion anymore - it’s about investor confidence, reputation, and long-term visibility. Susanne Berge Hansen (SBH): It’s similar in Norway. Managers want stability and regulatory consistency. By working closely with our Irish colleagues, we can compare and combine options to find the best fit for each client. The fact that this can now happen within the same organisation makes a big difference - it’s faster, simpler, and built on shared trust. EK: Clients increasingly expect that continuity. Having Ireland, Sweden, and Norway as well as our offshore offering in Jersey, Guernsey and Cayman under one group allows us to offer local presence and international reach in a single connected network of expertise. Enhancing expertise & innovation EK: We’ve already seen teams working more closely together since the integration. How is that translating into client opportunities right now? SBH: It’s already changing how we think. For example, Highvern’s Irish team has deep experience in areas like debt and private credit, while our Nordic clients are exploring those same asset classes. We can now bring that knowledge straight into client discussions, rather than learning from scratch. JB: Yes and on our side, we’re supporting more clients who want digital access and data visibility. As part of a larger group with shared technology development, we’re now able to offer those tools faster. It’s a real, practical benefit that’s happening today. EK: And it’s two-way. We’re learning from the Nordic teams’ approach to client engagement -that mix of precision and partnership. You can already feel that shared energy across our teams. Having recently been successful on a pitch, referred from our Permian colleagues, for a Swedish manager looking to launch an Irish ICAV for their royalties’ fund, demonstrating not only the further jurisdictional reach but also the depth of expertise between both teams, the client was able to feel the benefit from the outset of the relationship. JB: At Permian, our values - caring, precise, and challenging - are really lived day to day. Joining a bigger group always raises questions about culture. How do you see that playing out? SBH: The key is that our values align. Highvern’s focus on quality, integrity, and client service mirrors what we’ve built at Permian. That means collaboration feels natural, you could see how quickly people connected - same mindset, just different accents! EK: That’s so true. The offsite really confirmed how strong that alignment is. Everyone’s ambitious but grounded, and that balance is what will help us scale without losing who we are. Impact for clients EK: Looking at the market today, what are the biggest topics your clients are focused on? JB: There’s a lot of attention on AIFMD II and ESG reporting. Clients want administrators who can not only comply but also help interpret what’s coming. Having a bigger, connected group means we can share insights and act faster when new regulation lands. SBH: Governance and data transparency are also high on the agenda. Clients expect partners who can combine strong regulatory understanding with modern digital delivery - and that’s exactly where we’re investing together as a group. EK: We’ve become one group with a shared purpose, and clients are already seeing the benefits - broader expertise, deeper resources, and a network that connects Ireland, the Nordics, and beyond. Not only does this extend to our Highvern and Permian colleagues, but also our strong network of intermediary relationships in each jurisdiction to help meet our clients needs. JB: It’s an exciting time. We’re not talking about a distant future - the collaboration is happening now, and it’s energising our teams and clients alike. You can feel the momentum. With a shared purpose and connected teams, we are already delivering enhanced onshore fund expertise, deeper resources, and seamless solutions for our clients – today and into the future.
November 6, 2025
As ESG regulation becomes a central part of the investment ecosystem, fund administrators take on a broader role. Agata Bremer, ESG Director at Permian, reflects on how this development builds on the existing strengths of fund administration — why administrators are uniquely positioned to deliver ESG services, and what it takes to adapt.
October 27, 2025
Meet Eleona Skreosen, Fund Administrator at Permian. With a background in Sustainable Finance and experience across hedge funds and health tech, she shares what drew her to Permian — and what makes her work here exciting
September 24, 2025
Jannike Ludvigsson, Senior ESG Advisor at Permian, answers key questions about the European Supervisory Authorities’ (ESAs) latest update on Sustainable Finance Disclosure Regulation (SFDR).
August 18, 2025
Several interesting publications from public authorities regarding the Sustainable Finance Disclosure Regulation EU 2019/2088 (SFDR) and linked sustainability regulations have been made during June and July 2025. Our main takeaways for Swedish and Norwegian AIFMs are listed below.
August 12, 2025
On 25 June, the Norwegian Financial Supervisory Authority (the “NFSA”) published a report on Norwegian asset manager’s compliance with the SFDR.
July 4, 2025
Dear clients, business partners and colleagues, As the long, sunny days of summer arrive, we extend our warmest wishes for a refreshing and enjoyable holiday season. In the past six months we have strengthened our team with talented new colleagues and sustained strong growth across our core services. We also joined forces with Highvern , broadening and deepening the support we provide and we are now present across seven jurisdictions. We are now using Allvue as our main fund administration platform. With Allvue in place, we have a highly efficient and secure IT solution in place, handling everything from accounting to all elements of fund administration, as well as allowing integrations to other systems through open APIs. Allvue also offers a professional Investor Portal that enables seamless investor reporting, performance tracking and enhances investor interaction through interactive dashboards. With the solid backbone in place, Allvue will strengthen the overall quality of our service, fully aligned with our commitment to delivering “Everything Correct” . We have also reinforced our ESG commitment by developing tailored ESG services specifically designed to support and offload AIF managers. These milestones reflect our dedication to tech innovation, operational excellence, our ESG ambitions, and above all your success. We are already energized by the progress we have made so far this year and are eager to pick up where we left off once the break is over. Until then, thank you for your trust and collaboration. From all of us at Permian, have a wonderful, restful and sun-filled summer holiday!
June 10, 2025
At Permian, we believe that sustainability is more than just a regulatory requirement—it’s an essential part of creating long-term value to investors in the private equity markets. As the ESG landscape continues to evolve at a rapid pace, we’re committed to being a trusted partner for AIF managers navigating this complex terrain. The introduction of regulations such as the Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy has brought both challenges and opportunities for fund managers. Understanding the requirements, aligning with investor expectations, and integrating ESG into operations can feel overwhelming and time consuming. That’s why we’re developing tailored ESG services specifically designed to support and offload AIF managers in their journey toward compliance and sustainable growth. Services that are a natural extension of Permian’s long-standing values: Precise, Challenging, and Caring. “At the heart of our commitment is a focus on finding and building the best, most efficient solutions to support the ESG journey of AIF managers. We understand the complexities fund managers face and are dedicated to making the process as easy and seamless as possible,” says Agata Bremer, Head of ESG at Permian. By leveraging innovative and effective tools, streamlined processes, and expert guidance, we aim to reduce the efforts and any burden of compliance and create clarity in an otherwise complex regulatory landscape. Our approach is hands-on, operative and collaborative. Through ongoing dialogues with clients, including workshops and one-on-one support, we aim to uncover pain points and identify practical solutions. Whether it’s simplifying ESG reporting, aligning investment strategies with sustainability goals, or addressing regulatory obligations, our goal is to provide actionable guidance that truly makes a difference.  We’re excited about the opportunities ahead and look forward to helping AIF managers turn handling of sustainability from a challenge into a competitive advantage. Together, we can create lasting impact for businesses, investors, and the environment.
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