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ESA publishes final SFDR RTS: The main changes – Current need for action

On 4 February 2021 the European Supervisory Authorities (ESA) published their final reporton the Regulatory Technical Standards (RTS) for SFDR.This results in a number of updates that urgently need to be taken into consideration in the compliance reporting. To keep you up to date, we have summarised the most important upcoming changes and our recommendations for action.

The main changes in this final draft RTS, compared to the previous draft RTS (published within the Joint Consultation Paper on 23 April 2020) are:

  1. PAIs (Principal Adverse Impacts) an update of the list of indicators for entity-level principal adverse impacts.
  2. Article 8 pre-contractual and periodic disclosure templates have been updated (compared to the mockups published in September 2020).
  3. Article 9 pre-contractual and periodic disclosure templates have been published (for the first time).
  4. Information on the website regarding Article 8 and 9 products has been updated.
  5. DNSH (Do Not Significantly Harm) – details on how to assess whether sustainable investments do not significantly harm.
  6. Clarification on multi-option products has been provided.

Key challenges include:

  1. Defining clear monitoring of measures for pre-contractual and periodic reports.
  2. Adjusting to the mock-ups on pre-contractual and periodic reports included in the RTS.
  3. Historical data in the periodic report needs to take into account averaging over each period to avoid “window dressing”.
  4. Extended requirements for product information on the webpage.
  5. Methodology to select indicators based on probability of occurrence and severity.
  6. For MOPs: information for all options need to be provided either as annexes or through links.
  7. Discretionary mandates and other products for which requirements were uncertain will need to comply, even if in password-protected section of the webpage to keep confidentiality.

Implementation with acarda:

  1. Based on your requirements, our experts will develop an action plan with you. Optionally, our partner Simmons & Simmons can also support you in terms of legal issues.
  2. Our SFDR software module is already available today for mapping the above challenges. We will gladly present you the data management including the acquisition of ESG data, the monitoring of PAI criteria and the generation of exemplary SFDR reports, templates and websites for all Article 6, 8 and 9 portfolios.
  3. The SFDR module is part of our acarda platform for data management and regulatory reporting. Based on a central database, you can also map PRIIPS and MiFID, KIDs, Solvency II, AFIMD, CRR and many other reports.

Johannes Waldheim, Head of Productmanagement at acarda welcomes the draft RTS improving ESG reportings:

“Active and passive funds must both provide the same information with equal information requirements. A passive fund, can simply refer to the index, but must declare this. A SDFR-compliant and early positioning of products according to articles 6, 8 and 9 with all documents and calculations is essential. With a SFDR module integrated in our reporting platform we support our clients with ESG-compliant data, method alignment, all calculations and documents as well as web services according to SFDR Level 1 required by 10 March 2021.“

Press contact
Jessica Schreiner

Phone:+49 15 25 47 62 361
Email: jessica.schreiner@acarda.de

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