ESA Joint Committee · sfdr-41 Final

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

Regulation
SFDR
Answered
2025-11-04
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

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 actions taken, planned or targets set “to avoid and reduce” PAI referred to in Article 6(2) of SFDR Delegated Regulation? Should the financial market participant include a description of what actions the financial market participant will take if the PAI reaches a certain level?

Answer

Under the description of actions taken, planned or targets set “to avoid and reduce” PAI referred to in Article 6(2) SFDR Delegated Regulation, in order for that description to be fair, clear and not misleading, the financial market participant should, for each of the identified PAI, include (or refer to) information on how the financial market participant assesses the need to take action (e.g. any relevant thresholds or criteria that trigger actions to mitigate the PAI), the actions taken the previous year and actions planned or targets set for the coming year.

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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