ESA Joint Committee · sfdr-70 Final

Should financial products calculate top investments or shares of investments in their periodic disclosures under Chapter V and Annexes IV and V of the SFDR Delegated Regulation in a specific way over

Regulation
SFDR
Answered
2025-08-04
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Question

Should financial products calculate top investments or shares of investments in their periodic disclosures under Chapter V and Annexes IV and V of the SFDR Delegated Regulation in a specific way over the reference period, such as quarterly snapshots or a single snapshot at the end of the year?

Answer

Since SFDR financial product periodic disclosures only complement the sectoral legislation referred to in Article 11(2) SFDR with specific sustainability-related disclosures, the methodologies for periodic disclosures stem from those underlying sectoral rules referred to in Article 11(2) SFDR. Therefore, the ESAs cannot impose a specific way of calculating investments in the periodic reports in a practical application SFDR Q&A applying to all the sectoral legislation in Article 11(2) SFDR.
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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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