ESMA · ESMA_QA_2662 Forwarded to EC/Public Consultation/Other

Investment firms’ SFDR disclosure obligations

Regulation
Regulation (EU) 2019/2088 - Sustainable Finance Disclosure Regulation (SFDR)
Article
Art 2.1(b)
Topic
Disclosures
Submitted
2025-10-10

Question

In the case where a financial market participant, such as a fund manager (delegator), delegates the portfolio management of a fund to an investment firm (delegatee), is the delegatee investment firm subject to the same SFDR disclosure obligations for the portfolio management it performs for that fund as when it deals with discretionary portfolio management mandates with end investors?
No answer published yet.

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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