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)
⚠
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
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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