ESMA · ESMA_QA_2460 Forwarded to EC/Public Consultation/Other

Financial products’ PAI disclosures

Name: Financial products’ PAI disclosures: ESMA Q&A — EU Financial Regulatory Q&A
Creator: European Securities and Markets Authority
License: https://creativecommons.org/licenses/by/4.0/

Regulation: Regulation (EU) 2019/2088 - Sustainable Finance Disclosure Regulation (SFDR)
Article: Article 7.1
Topic: Disclosures
Submitted: 2025-03-11

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Question

a) Can a financial product referred to in Article 2(12) SFDR consider the principal adverse impacts of its investment decisions on sustainability factors according to Article 7(1) if the financial market participant manufacturing that product does not consider the principal adverse impacts of its investment decisions on sustainability factors under Article 4(1)(a) or 4(3)-(4) SFDR? b) Can financial products referred to in Article 2(12) SFDR satisfy the client’s sustainability preferences pursuant to point (c) of Article 2(7) of Commission Delegated Regulation (EU) 2017/565 or point (c) of Article 2(4) of the Commission Delegated Regulation (EU) 2017/2359 in any other way than by considering the principal adverse impacts of its investment decisions on sustainability factors referred to in Article 7(1) SFDR

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This Q&A is published by European Securities and Markets Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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