ESA Joint Committee · sfdr-32 Final

If a financial market participant with more than 500 employees does not market or make available any financial products as defined in Article 2(12) SFDR, does the financial market participant still ha

Regulation
SFDR
Answered
2022-11-17
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Joint Committee Q&As are published in consolidated PDF documents without explicit question/answer delimiters. Section boundaries below are identified automatically and may occasionally be imprecise.

Question

If a financial market participant with more than 500 employees does not market or make available any financial products as defined in Article 2(12) SFDR, does the financial market participant still have to comply with the requirement to publish a statement on consideration of principal adverse impacts under Article 4(1)(a) SFDR?

Answer

The scope of the disclosures under Article 4(1)(a), 4(3) or 4(4) SFDR is limited by the definitions of “financial market participant” in Article 2(1) SFDR, (i.e. credit institutions and investment firms should only cover their portfolio management activities and e.g. not their own account). Within this scope, financial market participants have to consider all investment decisions for the disclosures under Article 4(1)(a), 4(3) or 4(4) SFDR, irrespective of whether the financial market participant’s investment decisions are made through financial products or in any other way.
View original on ESA Joint Committee (EBA, ESMA, EIOPA) ↗

This Q&A is published by ESA Joint Committee (EBA, ESMA, EIOPA) and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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