ESA Joint Committee (EBA, ESMA, EIOPA) Q&A Database

Point 11 of Annex II, Methodology for the presentation of risk, defines the return over each period as the natural logarithm of the ratio of the price at the market close at the end of the current per

PRIIPs

In the case of actively managed funds (meaning there is not a benchmark that can reflect the performance) that have been valued on a weekly basis for more than 10 years (i.e. that currently have only

PRIIPs

According to point 16 (a) of Annex IV, the assessment of the appropriateness of a benchmark or proxy depends, inter alia, on the risk-return profile where the benchmark or proxy and the PRIIP fall int

PRIIPs

The main difference between Category 2 and Category 3 is, in accordance with Annex II Part 1 Point 5, whether the condition of "constant multiple" is fulfilled. In the event where a UCITs product has:

PRIIPs

In assessing whether the use of a particular benchmark or proxy is appropriate, potential assets in which the PRIIP invests, consistent with the investment policy, must be taken into account (point 16

PRIIPs

When an FMP considers PAI at entity level and discloses a statement on its due diligence policies in accordance with Article 4(1)(a) or 4(3)-(4) of the SFDR, what is required under the description of

SFDR

PAI 6 (Table 2): The term ‘water usage’ is not defined in the RTS and is not a common term within the CDP nomenclature (water withdrawal, water discharge, water consumption and water recycled/reused).

SFDR

Should financial products calculate top investments or shares of investments in their periodic disclosures under Chapter V and Annexes IV and V of the SFDR Delegated Regulation in a specific way over

SFDR

Can a financial product disclosing under Article 9 SFDR, or a financial product disclosing under Article 8 SFDR partly making sustainable investments, disclose in its pre- contractual disclosure that

SFDR

Regarding 'COMMISSION DELEGATED REGULATION (EU) 2022/1288 of 6 April 2022' (supplementing Regulation (EU) 2019/2088). In Table 2, Annex I of the document, under the section 'Indicators applicable to i

SFDR

What is the meaning of ‘1 year’ and ‘> 1 year’ in the table in paragraph 18 of Annex IV of PRIIPs L2? Specifically, we wonder whether ‘1 year’ encompasses all Recommended Holding Periods (RHPs) under

PRIIPs

5. Should entry costs be included in the 10 000 EUR amount referred to point 90 of Annex VI of the PRIIPs Delegated Regulation?

PRIIPs

According to the PRIIPs Delegated Regulation, if the MRM class changes to a different MRM class, the PRIIP manufacturer shall attribute the corresponding MRM class to the MRM class which the PRIIP has

PRIIPs

Point 35 of the Annex IV on Performance Scenarios states that ‘the values to be shown for the intermediate periods for the unfavourable, moderate and favourable scenarios shall be calculated in accord

PRIIPs

Point 26 of Annex IV reads: ‘For Category 3 PRIIPs, the following adjustments shall be made for the calculation of the stress scenario compared to the calculation for Category 2 PRIIPs: (a) infer the

PRIIPs

How should values in currencies other than EUR be converted to EUR? E.g. at the point of reporting, the point of the impact or an average value in EUR of values in currencies converted to EUR at diffe

SFDR

Are financial market participants obliged to publish the pre-contractual or periodic product templates on their websites based on the SFDR, or does that depend on the sectoral law on publication of th

SFDR

Should a fund invest in for example cars or real estate assets, through special purposes vehicles ("SPVs") or holding companies, would those SPVs/holding companies be considered as the "companies" cov

SFDR

Should PAI indicator 4 in Table 1, Annex I of the SFDR Delegated Regulation ("Exposure to companies active in the fossil fuel sector") be calculated on a look-through (i.e. share of fossil fuel activi

SFDR

Can a financial market participant rely on disclosures under Article 6(1) second sub- paragraph of the SFDR (which allow financial market participants to disclose in pre- contractual disclosures that

SFDR

What information should financial market participants disclose about financial products passively tracking a PAB or CTB?

SFDR

a) In situations where financial market participants delegate management, is the application of the definition of "sustainable investment" in Article 2, point (17) SFDR an exclusive prerogative of the

SFDR

Following the answer to Q&A V.9, where financial products are passively tracking Paris Aligned Benchmarks (PABs) and Climate Transition Benchmarks (CTBs), it can be considered they do not fall under A

SFDR

For financial products falling under Article 8 or 9 SFDR, where the financial market participant making available those products is a registered AIFM which has not set up a website, must that register

SFDR

Can a sustainable investment pursuant to Article 2(17) SFDR also be made by investing in another financial product, e.g. a UCITS fund?

SFDR

In line with SFDR Delegated Regulation and the SFDR Q&As (JC 2023 18), a UCITS management company disclosing its UCITS under Article 9 SFDR may next to "sustainable investments" (i.e. in the "remainin

SFDR

Should PAI indicator 6 in Table 1 of Annex I of the SFDR Delegated Regulation ("Energy consumption intensity per high impact climate sector") be disclosed on an aggregated basis (i.e. each high impact

SFDR

With regard to how a financial market participant (e.g. a UCITS management company) discloses PAI indicator 1 in Table 1 of Annex I of the SFDR Delegated Regulation in relation to its financial produc

SFDR

I am trying to figure out how exactly to calculate the share of sustainable investment that qualify as environmentally sustainable under the EU Taxonomy (SDFR Template, Annex II, first question). Let'

SFDR

Given the Commission’s interpretative Q&A II.1 notes that sustainable investments can be measured at economic activity and at the investment level, how can financial products do this in practice? The

SFDR

Do FX forwards fall within the scope of the PRIIPs Regulation?

PRIIPs

What is the difference between a "benchmark" and a "proxy" within the meaning of the Delegated Regulation? If an AIF does not have a sufficient historical price time-series and the PRIIP manufacturer

PRIIPs

Please clarify the term "PRIIPs open to subscription"?

PRIIPs

Should the costs disclosed in table 1 (cost over time) and table 2 (total cost) be aligned for year 1?

PRIIPs

Should a KID disclose cost information and scenario information about 1 year and half the RHP in case the investors may not be allowed to exit a PRIIP before the end of the RHP?

PRIIPs

Could an artificially created “synthetic” proxy be considered an appropriate proxy in accordance with the PRIIPs RTS Annex II and Annex IV?

PRIIPs

Is currency risk described by Risk Element C applicable to investment funds, or should currency risk generally be considered by wrapper products / multi-option products only? In case currency risk is

PRIIPs

When sufficient history for the SRI calculation is not available to cover 5 years of data for a daily share class, can the PRIIP manufacturer decide to use a benchmark/proxy to cover up to 5 years of

PRIIPs

Taking into account Article 23(3) of Commission Regulation (EU) No. 583/2010, should the information on past performance in accordance with Article 8(3), first subparagraph of the PRIIPs Delegated Reg

PRIIPs

Does point 5(b) of Article 2 of the RTS – ‘an indication of whether the PRIIP manufacturer is entitled to terminate the PRIIP unilaterally’ concern i) market circumstances or ii) client specific circu

PRIIPs

The new wording in Article 2(2a)(b) of the ‘What is this product?’ section appears to duplicate the requirement already included in the RTS Article 6 (in the “How long should I hold it and can I take

PRIIPs

Could you confirm that for what concerns the calculation of performance scenarios, as specified in Annex IV, point 7, the manufacturer must always use monthly data even if the NAV is available at high

PRIIPs

In Annex IV, Case 3 for PRIIPs referred to in point 1 of Annex VIII without sufficient historical data and with no benchmark, or with a benchmark without sufficient historical data, or any other Categ

PRIIPs

If a product, linked to a single ISIN code, is available in both the single and recurring premium versions, it is possible to provide a representation of the riskier version of the two by reporting in

PRIIPs

Could you confirm if products with recurring premiums are to be modelled as Category 2 PRIIPs or Category 3 PRIIPs?

PRIIPs

In the case of an investment fund (UCITS or AIF), can the manufacturer of the PRIP be an entity to which collective portfolio management functions, or other functions, have been delegated to by the fu

PRIIPs

In life annuities, should the sum of rents paid up to the period be considered in the minimum scenario?

PRIIPs

Could you confirm if manufacturers of insurance-based investment products are allowed to signpost to KIDs produced by fund managers instead of proper SIDs in their IBIP MOPs? What happens when the RHP

PRIIPs

PAI consideration: What is the meaning of “consider” in Article 7(1), point (a), SFDR? Could “consideration” of principal adverse impacts by a financial product mean that a financial product only disc

SFDR

500 employee principal adverse impact (PAI) threshold: For the purposes of Articles 4(3)- 4(4) SFDR, should “the average number of 500 employees” be understood to include workers who are assigned to t

SFDR