ESA Joint Committee · sfdr-55 Final

Would a discretionary mandate that invests according to Investment Guidelines stipulated by the client be regarded as a financial product falling under Article 8 or Article 9 SFDR?

Regulation
SFDR
Answered
2022-11-17
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

Would a discretionary mandate that invests according to Investment Guidelines stipulated by the client be regarded as a financial product falling under Article 8 or Article 9 SFDR?

Answer

Whether a financial product is invested according to a discretionary mandate or client guidelines does not affect the potential application of Articles 8-11 SFDR to it.

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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