SFDR: Level 2 implementation postponed to 1 January 2023

As expected, the EU Commission recently announced that the regulatory technical standards (RTS) for the SFDR will not come into force until 1 January 2023. This gives asset managers a bit more time to provide sustainability disclosures in sales prospectuses, annual reports and on websites in line with the regulation.

However, the first date for mandatory reporting on principal adverse impact (PAI) of investment decisions at company level is not postponed. The collection and monitoring of PAI will still be required from 1 January 2022, as will the reporting of sustainability preferences in accordance with MiFID from 2 August 2022.

Despite the postponement of the pre-contractual reporting requirements, ESG fact sheets must therefore be prepared in compliance with the SFDR as early as next year, insofar as they concern Art 8 and Art 9 funds.

In any case, we advise adapting the regulatory reporting system to the upcoming changes in good time; ideally with a holistic automated reporting solution.  

Our experts will be happy to advise you on the details.