ESA Joint Committee · sfdr-60 Final

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'

Regulation
SFDR
Answered
2024-07-25
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

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's take for example company X: According to company X's latest annual report, 18% of sales, 78% of CAPEX and 23% of OPEX qualify as Taxonomy aligned. So how much of an investment in company X would qualify as sustainable under the EU Taxonomy?

Answer

The methodology for the calculation of the proportion of taxonomy-aligned investments referred to in that section is set out in Articles 15 and 17 of the SFDR Delegated Regulation. Applying this methodology to an investment in a general financing instrument cited by the question, the contribution of such an investment to the taxonomy-aligned investments of a financial product in the pre-contractual template in Annexes II and III would be any of the percentages of the investment cited by the question, depending on whether turnover, capital expenditure (CapEx) or operating expenditure (OpEx) is chosen by the financial product for the Annex II-III disclosure. By contrast, in the periodic disclosures in the templates contained in Annexes IV and V of the SFDR Delegated Regulation require the disclosure of the proportion of Taxonomy-aligned investments by turnover, CapEx and OpEx. For illustrative purpose, this is an example of the investments of a financial product: Amount of the investment (in €) Turnover KPI for Taxonomy alignment CapEx KPI for Taxonomy alignment OpEx KPI for Taxonomy alignment Company X (general financing instrument) €100 18% 78% 23% Company Y (general financing instrument) €50 4% 42% 6% Cash €30 Not in the numerator Not in the numerator Not in the numerator Sovereign bonds €20 Not in the numerator Not in the numerator Not in the numerator Total investments (calculations in footnotes) €200 10%10 49,50%11 13%12 Total investments without sovereign bonds (calculations in footnotes) €180 11.11%13 55%14 14.44%15 10 100 . 18 100 + 50 . 4 100 200 = 18+2 200 = 20 200 =10% 11 100 . 78 100 + 50 . 42 100 200 = 78+21 200 = 99 200 =49,50% 12 100 . 23 100 + 50 . 6 100 200 = 23+3 200 = 26 200 =13% 13 100 . 18 100 + 50 . 4 100 180 = 18+2 180 = 20 180 =11.11% 14 100 . 78 100 + 50 . 42 100 180 = 78+21 180 = 99 180 =55% 15 100 . 23 100 + 50 . 6 100 180 = 23+3 180 = 26 180 =14.44% For this example, the proportion of Taxonomy-aligned investments made by this financial product is 10% according to the turnover, 49.50% according to CapEx and 13% according to OpEx (figures represent all investments including sovereign bonds). Disclosures of the proportion of Taxonomy-aligned investments of a financial product Articles 15, 19, 55 and 62 of the SFDR Delegated Regulation lay down the rules applicable to financial products regarding the disclosures of the minimum extent of their Taxonomy-aligned investments. For the financial products referred to in Article 5 or 6 of Regulation (EU) 2020/852, pre- contractual templates in Annexes II and III of the SFDR Delegated Regulation should include the disclosure of the minimum extent of Taxonomy-alignment of investments of the financial product (see Q&As VII.8 and VII.9). In accordance with Articles 15(3) and 19(3) of the SFDR Delegated Regulation, this minimum extent is measured by turnover, except if the financial market participant has decided that a more representative calculation is given when that degree is measured by CapEx or OpEx. In such case, the financial market participant should disclose the reason for that decision, including an explanation of why that decision is appropriate for investors in the financial product (see Articles 15(3)(a) and 19(3) of the SFDR Delegated Regulation).  For illustrative purpose only, below are the pie charts of the hypothetical portfolio used as an example above (in this example, the financial market participant has decided to make a commitment to have minimally 5% taxonomy-aligned investments, regardless of the proportion of sovereign bonds in the product’s investments): For the financial products referred to in Article 5 or 6 of Regulation (EU) 2020/852, periodic templates in Annexes IV and V of the SFDR Delegated Regulation should include the proportion of Taxonomy-aligned investments made by the financial product during the 5% 95% 1. Taxonomy alignment of investments including sovereign bonds* Taxonomy-aligned (no fossil gas & nuclear) Non Taxonomy-aligned* 5% 5% 95% 2. Taxonomy alignment of investments excluding sovereign bonds* Taxonomy-aligned (no fossil gas & nuclear) Non Taxonomy-aligned* 5% reference period covered by the periodic disclosure. Those calculations should be made in accordance with Article 55(2) and 62(2) of the SFDR Delegated Regulation).  For illustrative purpose only of periodic disclosures of Taxonomy-alignment, below are the bar charts of the hypothetical portfolio used as an example:

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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