Are financial market participants obliged to publish the pre-contractual or periodic
product templates on their websites based on the SFDR, or does that depend on the
sectoral law on publication of th

Question

Are financial market participants obliged to publish the pre-contractual or periodic
product templates on their websites based on the SFDR, or does that depend on the
sectoral law on publication of the documents referred to under Article 6(3) or 11(2) SFDR
to which the templates have to be attached?

ESA Joint Committee (EBA, ESMA, EIOPA) · Accepted Answer

Article 10 SFDR refers to the information
under Article 8, 9 or 11 of that Regulation, but not the actual documents under 6(3) or
11(2).
In order to fulfil the requirements in Article 10(1)(c)-(d) SFDR, there is no need to publish the actual
documents referred to in Article 6(3) and 11(2) SFDR. Nevertheless, the ESAs’ supervisory
expectation is that the obligation to publish the information referred to in Article 10(1)(c)-(d) (i.e. the
information referred to in Article 8,9 and 11 SFDR) should be fulfilled by publishing the templates in
Annexes II-V of the SFDR Delegated Regulation.

Are financial market participants obliged to publish the pre-contractual or periodic product templates on their websites based on the SFDR, or does that depend on the sectoral law on publication of th

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