Sustainable Finance: Update on the Application of the Sustainable Finance Disclosure Regulation (“SFDR”)

The Sustainable Finance Disclosure Regulation (“SFDR”) sets out sustainability-related disclosure requirements for financial market participants and financial advisers. Its aim is to improve the transparency and comparability of sustainability-related disclosures for end investors, and to reduce the occurrence of adverse sustainability impacts of investment decisions and greenwashing.

The SFDR and related Regulatory Technical Standards which specify the required content and presentation of information to be disclosed are part of a broader range of European Commission (“EC”) initiatives on sustainable development.

On 6 April 2022, the EC published the final version of the Regulatory Technical Standards (“RTS”) under the SFDR.

The RTS contain the final prescribed-form templates for:

• Annex I: The statement for presenting key performance indicators under the principal adverse impacts regime.
• Annex II: Pre-contractual disclosures for the financial products referred to in Article 8 of the SFDR – i.e. a financial product which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.
• Annex III: Pre-contractual disclosures for the financial products referred to in Article 9 of the SFDR – i.e. a financial product which has sustainable investment or a reduction in carbon emissions as its objective.
• Annex IV: Periodic disclosure for the financial products referred to in Article 8.
• Annex V: Periodic disclosure for the financial products referred to in Article 9.

Financial market participants and financial advisers should now familiarise themselves with the mandatory reporting templates for pre-contractual and periodic disclosures as well as the Principal Adverse Sustainability Impacts Statement in order to be in a position to make these disclosures from the application date – i.e. 1 January 2023.

How EisnerAmper Ireland can help

As Partner in EisnerAmper’s Governance, Risk & Compliance Group, Carina Myles advises financial service providers on risk, regulatory and compliance-related matters. EisnerAmper’s specialist services include:

• Supporting organisations through regulatory change;
• Provision of bespoke board support and training;
• Designing and developing integrated risk and compliance frameworks;
• Preparing compliance briefings for discussion with the board; and
• Supporting the board in responding to and implementing any changes required relating to evolving needs.

If we can help you or your business in any way, please do get in touch – we’d be delighted to help.

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