Can a financial product disclosing under Article 9 SFDR, or a financial product disclosing under Article 8 SFDR partly making sustainable investments, disclose in its pre- contractual disclosure that

Under the SFDR Delegated Regulation, in the tick box at the start of Annexes II and III of the Delegated Regulation, financial products disclosing under Article 8 SFDR are required to publish (i) a minimum percentage above zero of total sustainable investments (SI) if the product intends to partly make sustainable investments, and Article 9 SFDR financial products are required to publish (ii) two minimum percentages on the subsets of environmental sustainable investments and social sustainable investments. These percentages are minimum commitments, so the two subsets (X% and Y%) may not equal the total minimum proportion of sustainable investments (Z%) in the asset allocation section of Annexes II and III of the SFDR Delegated Regulation. While focus (e.g. in sustainability preferences) is on the total minimum commitment (Z%), the ESAs recommend as best practice that where X% and Y% do not add up to Z%, the financial market participant should include an explanation to clarify why this is the case in the asset allocation section in the template in Annexes II and III.