Article 6, Article 8 and Article 9 disclosures Five fall within Article 8 SFDR and five fall within Article 9. Following this The SFDR and other regulations are also aligned with the European Green Deal, which aims to see the EU carbon neutral by 2050. Article 6 covers funds . These are the articles that require the RTS and implementing technical standards (ITS) to be drafted and adopted. around the approach for Article 6, 8 and 9 products under the EU Sustainable Finance Disclosure Regulation (SFDR). methodologies and presentation of disclosures pursuant to Article 2a, Article 4(6) and (7), Article 8(3), Article 9(5), Article 10(2) and Article 11(4) of Regulation (EU) 2019/2088. Article 4 of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability related disclosures in the financial services sector Of these recent regulations, the Sustainability Related Financial Disclosure Regulation (SFDR) is the closest to being applied and will Since these areas don't impede the application of existing SFDR provisions, actors subject to the regulation must comply as of now. The Sustainable Finance Disclosure Regulation (SFDR) requires all financial market participants in the EU to disclose ESG issues, with additional requirements for products that promote ESG characteristics or that have sustainable investment objectives. In the first major move by a regulator to codify ESG disclosure rules, the EU introduced the Sustainable Finance Disclosure Regulation (SFDR) on 10 March, 2021. Article 6 . In relation to UCITS, disclosures required under Article 6 of the Regulation (EU) 2019/2088 on the sustainability-related disclosures in the financial services sector (SFDR) and, if applicable, Articles 7, 8 or 9 of SFDR must be disclosed in their prospectuses. the meaning of "promotion" in the context of products promoting environmental or social characteristics. The ESG alphabet soup now includes numbers! 5 Taxonomy Regulation financial products) climate change mitigation and/or climate change adaptation. This means article 6 products will comprise a very diverse range of products from those with no consideration of . Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investments ("TR"), and amending Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector ("SFDR"), requires financial market participants, for financial products subject to Articles 8 and 9 of SFDR, to provide for . Firms must now comply with the SFDR's high-level disclosure requirements, including: Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (Text with EEA relevance) (SFDR, also known as ESG Regulation and Disclosure Regulation) For example, some asset managers categorise products as . The SFDR and other regulations are also aligned with the European Green Deal, which aims to see the EU carbon neutral by 2050. The Sustainable Finance Disclosure Regulation (SFDR) 1 empowered the European Supervisory Authorities (ESAs) 2 to develop draft regulatory technical standards (RTS) on taxonomy-related product disclosures.On 15 March 2021, the ESAs published a consultation paper on draft regulatory technical standards regarding the content and presentation of sustainability disclosures pursuant to Article 8(4 . The big question: Article 8 or Article 9? The article numbers refer to the articles in the level 1 text of the SFDR. Under Articles 8 and 9, funds undergo greater disclosure, with Article 9 undergoing the most disclosure. The Taxonomy is connected to and will support disclosure requirements under the Sustainable Finance Disclosure (SFDR) regulation. Article 8 products are deemed to be those that promote environmental and social characteristics, taking ESG criteria into account as part of the . how SFDR applies the 500-employee threshold for principal adverse impact (PAI) reporting on parent undertakings of a large group. Article 6 covers funds . I am an asset manager with 30 funds, 20 of which fall within Article 6 SFDR only. This information is set out in the terms and conditions below: 1. Article 6, 8 and 9 funds are the three classifications of investment strategy that will apply to Robeco's products under the EU's Sustainable Finance Disclosure Regulation.This new set of rules coming into effect from this year will force asset managers to reveal the differing levels of sustainability integration and focus of each investment strategy that they offer. The first phase of the legislation was introduced in March this year, requiring asset managers to publish both pre-contractual statements (e.g. This means article 6 products will comprise a very diverse range of products from those with no consideration of ESG characteristics at all, to those that do consider them to some extent, but not to such an extent as to be considered article 8 products. The initial SFDR provisions will take effect on March 10, 2021, with certain grey areas to be clarified subsequently by the European Commission. In Article 6, all managed products are included, irrespective of ESG credentials. In Article 6, all managed products are included, irrespective of ESG credentials. SFDR Article 8 funds - Net assets of SFDR Article 8 funds totalled EUR 3.7 trillion, making up 22% of the European fund market at the end of Q1 2021. Phase 1 went into effect on March 10 th, 2021. None have environmental objectives or promote environmental characteristics. Note: As above. The most visible and impactful element in the new SFDR regulation is the classification of funds and mandates in three categories, as laid out by Articles 6, 8 and 9 of the SFDR. Article 6 While Article 8 applies additional disclosure requirements to funds that fall within its scope, Article 6 of the Disclosure Regulations applies disclosure requirements to every type of investment fund within the scope of the Disclosure Regulation. The design of SFDR, and upcoming . SFDR imposes new transparency obligations and periodic reporting requirements on investment management firms at both a product and . SFDR brings new ESG disclosure rules for asset managers. in a fund's prospectus) and . Corrigendum to Commission Decision C (2021)4858 final of 6 July 2021 on the adoption . Sustainable Finance Disclosures Regulation (SFDR) Before you access the Stewart Investors website, we would like you to read & understand some important information about the site, what data we collect and how we use it. The abovementioned Articles were inserted in the SFDR through Article 25 of Regulation (EU) 2020/852 (the Taxonomy Regulation or the TR) which amends the SFDR. When you need to make meaningful like-for-like comparisons across funds that share characteristics, Refinitiv Lipper is the answer. Worked examplesallenovery.comGreat Fund Insights: SFDR and taxonomy regulation deadlines - What asset managers need to knowWhich of my funds fall within Article 6 vs Article 8?One of the most . Three fall within Article 8 . Articles 6 of the Taxonomy Regulation does the same for Article 8 of the SFDR. Where a financial product is not subject to Article 8(1) or to Article 9(1), (2) or (3) of Regulation (EU) 2019/2088, the information to be disclosed in accordance with the provisions of sectoral legislation referred to in Articles 6(3) and 11(2) of that Regulation shall be accompanied by the following statement: The Draft SFDR Amendment RTS covering how and to what extent investments underlying the financial product are in economic activities that qualify as environmentally sustainable under the EU Taxonomy Regulation require that the financial product under Art. On 22 October 2021 the European Supervisory Authorities (ESAs) published their final report on draft Regulatory Technical Standards (RTS) on the taxonomy-related disclosures for financial products subject to the disclosure requirements under Article 8 and Article 9 Sustainable Finance Disclosure Regulation (SFDR). Sustainable Finance Disclosure Regulation (SFDR) is a great opportunity for investors to demonstrate how serious they are about sustainability and ESG. The European Union's new Sustainable Finance Disclosure Regulation (SFDR) - also known as the Disclosure Regulation - comes into effect in March 2021. The SFDR fund categories: Article 6, Article 8 and Article 9. Given the official fast-tracking that the financial authorities in each country have given to the pre-contractual agreement editing, it has been up to the self-proclamation by asset managers to initiate their fund categorisation which has led to some discrepancies. 1 Sustainable Finance Disclosures Regulation ("SFDR") Article 6 - Transparency of the integration of sustainability risks (Regulation (EU) 2019/2088) Introduction This document sets-out pre-contractual disclosures required to be made under Article 6 of SFDR by To enable comparison of financial funds, the new SFDR regulation requires funds and mandates to be considered and classified into three categories, as laid out by Articles 6, 8 and 9 of the SFDR. The regulation will increase the information available for investors about both the potential positive and negative impact of their investments and the related ESG risk. SFDR is taking a phased implementation approach over an extended timeframe. All products that are in scope of SFDR must comply with the article 6 disclosures. Where an article 8 SFDR financial product promotes environmental characteristics, the additional information that will need to be disclosed in pre-contractual documentation is the same as for Article 9 products, as . FMPs, or better said, producers of financial products that are described under article 8(1), 9(1), 9(2) and/or 9(3) of the SFDR regulation, will need to report via various means to their clients on the sustainability impacts related to the financial product. As of 1 January 2022, the regulatory requirements under the Taxonomy Regulation shall apply for financial products which are promoting (Art. All products that are in scope of SFDR must comply with the article 6 disclosures. "Article 9" products are so-called "dark-green" products with mainly sustainable investments. The main domiciles of SFDR Article 8 funds are Luxembourg (35%), France (16%), the Netherlands (13%), Sweden (13%) and Ireland (9%). Despite a recently announced delay and reduction in the number of disclosures that . 6 Taxonomy Regulation financial products) or have as their objective (Art. Among other duties, Article 6 of the SFDR includes obligations on financial market participants and financial advisers to disclose in the pre-contractual information regarding the financial product information on the impacts on sustainability risk in the performance of their activities and on the . To enable comparison of financial funds, the new SFDR regulation requires funds and mandates to be considered and classified into three categories, as laid out by Articles 6, 8 and 9 of the SFDR. Article 6 of the SFDR requires that financial market participants such as the AIFM to disclose the manner in which Sustainability Risks are integrated into investment decision-making and the results of the assessment of the likely impacts of Sustainability Risks on the returns of the Additional detail for SFDR delayed until July 2022. In Denmark, categorizing funds according to the new SFDR has become something of a tussle between Danske Bank, Finans Danmark, the Danish FSA and the EU Commission.. Now, it is Norway's turn. Explore this SFDR guide. Sustainable Finance Disclosure Regulation (SFDR) | 3 For example, some asset managers categorise products as . This regulation aims to reduce the risk of greenwashing by financial market participants . SFDR introduces obligations on financial market participants and financial advisors to disclose how they integrate ESG factors in their risk . This follows the ESAs' consultation paper issued in March 2021. On 6 May 2020, the UK Government re-published a revised draft of the Financial Services (Miscellaneous Amendments) (EU Exit) Regulations 2020, Regulation 22 of which provides that certain articles of the SFDR "are omitted". The SFDR and other regulations are also aligned with the European Green Deal, which aims to see the EU carbon neutral by 2050. All products that are in scope of SFDR must comply with the article 6 disclosures. The European Commission published the Sustainable Finance Disclosure Regulation, known as the SFDR or the Disclosure Regulation in November 2019 with an implementation date of 10 March 2021. The EU Sustainable Finance Disclosure Regulation (SFDR) is a new set of EU rules for increased comparability and reduced greenwashing among financial products. Article 8 can be viewed as a spectrum, ranging from the barest of green products with minimal screening of the underlying investments, to products that perhaps select . The stringency of SFDR regulations creates a number of challenges: And to ensure you are well prepared for the new regulation. disclosures under Articles 8(4), 9(6) and 11(5) of Regulation (EU) 2019/2088 (hereinafter Sustainable Finance Disclosure Regulation or SFDR). inclusion of annexes with amendments to the mandatory templates for financial products that promote environmental and/or social characteristics or have a sustainable investment objective as defined in the SFDR, so that they include additional disclosures for Article 5 and Article 6 products under the Taxonomy Regulation. 8 SFDR / Art. Sustainable Finance Disclosures Regulation ("SFDR") Article 10 - Transparency of the promotion of environmental or social characteristics and of sustainable investments on websites (Regulation (EU) 2019/2088) Introduction This document sets-out the firm-level disclosures required to be made under Article 10 of SFDR by On 10 March, the EU Sustainable Finance Disclosures Regulation took effect, requiring for the first time 1 Sustainable Finance Disclosures Regulation ("SFDR") Article 6 - Transparency of the integration of sustainability risks (Regulation (EU) 2019/2088) Introduction This document sets-out pre-contractual disclosures required to be made under Article 6 of SFDR by - Ignore all the rows shaded in Schedule 1. Six-month delay to Level 2 gives European Commission time to address continued confusion, says law firm Fieldfisher. The draft Regulatory Technical Standards (RTS) to supplement the Sustainable Finance Disclosure Regulation (SFDR) have been issued by the European Supervisory Authorities (ESAs) and are available here.The RTS are not expected to come into force until 1 January 2022. By way of derogation from paragraph 2 of this Article, where no EU Climate Transition Benchmark or EU Paris‐aligned Benchmark in accordance with Regulation (EU) 2016/1011 of the European Parliament and of the Council (20) is available, the information referred to in Article 6 shall include a detailed explanation of how the continued effort of . Overview. The SFDR and the Taxonomy Regulation (collectively, the "ESG Regulations") form part of a package intended to move sustainable investment objectives to the core of the financial system in the EU, and to help end investors analyze and judge financial products by reference to social and environmental impact and sustainability. Important Information. Meanwhile, Article 7 of the Taxonomy Regulation applies the following boilerplate pre-contractual and periodic reporting disclosure to all otherwise in-scope financial products that are not "sustainable investments" and that do not promote their ESG . The Sustainable Finance Disclosure Regulation (SFDR), also known as Disclosure Regulations, came into force on 10th March 2021, imposing new transparency and sustainability-related disclosure requirements to the financial services sector. the application of SFDR product rules to portfolios and dedicated funds. MSCI's proposed approach to the key SFDR distinctions are based on assumptions and client feedback as explained in The SFDR will have big impact on asset managers, banks and fund brokers. 2. The SFDR is designed to improve and standardise investment firms' ESG reporting, providing greater transparency for investors. The basics of SFDR. However, the classification element of the regulation creates a hierarchy that could lead to a belief that Article 8 and 9 funds are always 'better' products than Article 6 funds. The European Commission's attempt to clarify requirements for funds under the Sustainable Finance Disclosure Regulation (SFDR) is potentially "lowering the bar" for Article 8 funds, according to James Tinworth, Funds and Financial Services Partner at law firm Fieldfisher. Given the definitions and provisions contained in the SFDR, the AMF anticipates that products presenting themselves as "having as their objective sustainable investment", as described in Article 9 of the said regulation, will implement "significantly binding" approaches within the meaning of AMF position-recommendation DOC-2020-03. Article 6, Article 8 and Article 9 disclosures Article 6 of Taxonomy Regulation - Financial Products Promoting Environmental Characteristics Subject to Article 8 SFDR. the application of Article 9 of SFDR and. Article 6 of the SFDR requires that financial market participants such as the AIFM to disclose the manner in which Sustainability Risks are integrated into investment decision-making and the results of the assessment of the likely impacts of Sustainability Risks on the returns of the "Article 6" products are all other types of products without environmental and social characteristics or sustainable investments. Since then financial market Regulation - Article 6 Funds What to consider when integrating sustainability risk into the investment decision making process? This phase sets specific rules for how and what sustainability-related information companies need to disclose. SFDR Regulation. fall within Article 6 SFDR only. In the upcoming weeks we will publish a blog series focusing on the SFDR, the obligations, the timelines, the definitions and the Adverse Sustainable Impacts Statement to help you get your head around the subject. As previously trailed, firms will be expected to comply with the primary legislation on a best efforts basis from 10 . The SFDR Regulation stands for the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation). On 10 th March 2021, SFDR came into effect, marking the start of a significant transition for the financial services sector. Article 2(17) of the SFDR consistent with the content, methodologies, and presentation of indicators in relation to adverse impacts referred to in Article 4(6) and (7) SFDR. The European Union has delayed the second phase of The Sustainable Finance Disclosure Regulation ( SFDR) by six months. The information is provided "as is" and does not constitute legal advice or binding interpretations of the SFDR. Article 6 . Although the regulation has not come into effect in the country yet, it is expected to do so in 2022, and players are divided on how to understand the rules. 9 SFDR / Art. The Sustainable Finance Disclosure Regulation (SFDR) comes into force on the 10th of March 2021. There are three distinct categories, known by the name of the part of the SFDR regulation that applies in each case: Article 6 products are those which only assess and address sustainability risks. 4. SFDR: Four Months After Its Introduction Article 8 and 9 Funds in Review Executive Summary . Although SFDR is EU legislation, 60 percent of UK-domiciled fund assets have so far been registered under the regulation, either as Article 6, 8, or 9 (non-ESG, 'light green', or 'dark green', respectively). Article 6 requires a Manager to include descriptions of the following in the prospectus of The SFDR defines sustainable investment as an investment in an economic activity that contributes to an environmental or social objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices. Article 7 of Taxonomy Regulation - Financial Products Qualifying Under Article 6 SFDR Where a financial product is not subject to articles 8 or 9 SFDR, the following additional statement is . Under Articles 8 and 9, funds undergo greater disclosure, with Article 9 undergoing the most disclosure. Each fund had to be self-classified by the institution into one of three categories: Article 6, 8 or 9. 5 and 6 of the EU Taxonomy Regulation calculates the extent of taxonomy alignment of . Article 6(1)(a) Article 6(2)(a) N / A 10 March 2021 2 Principal Adverse Impact Statement Managers must decide: (a) to implement a due diligence policy with respect to the principal adverse impacts of its investment decisions on sustainability factors; or (b) provide an explanation as to why the manager does not consider such adverse impacts. The SFDR defines sustainable investment as an investment in an economic activity that contributes to an environmental or social objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices. Each fund had to be self-classified by the institution into one of three categories: Article 6, 8 or 9. SFDR requires fund managers to categorise their funds between Article 6 (not having a specific ESG investment objective), Article 8 ('light green') and Article 9 ('dark green'). 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