ESA Joint Committee · sfdr-71 Final
For their own products and - if offered - in case of MOPs, for products of other financial market participants, the application date of SFDR Delegated Regulation is 1 January 2023. How should a financ
- 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
For their own products and - if offered - in case of MOPs, for products of other financial
market participants, the application date of SFDR Delegated Regulation is 1 January 2023.
How should a financial market participant offering a MOP collect the disclosure templates
from other financial market participants before or just in time for 1 January 2023? Would
it be possible to work with hyperlinks per default (e.g. as well in the periodic reporting)?
Answer
Hyperlinks are allowed only for pre-contractual disclosures under Article 20(5) and 21(5) of the
Delegated Regulation. They are not allowed for periodic disclosures. For pre-contractual
disclosures they are only allowed when the Multi-Option Product (MOP) has such a high quantity
of underlying options that it would make the provision of the respective disclosures for each
underlying investment option in a clear and concise manner difficult due to the number of
documents required. Ahead of the 1 January 2023 application date, insurance undertakings
providing MOPs should request the underlying option disclosures from the financial market
participant providing them.
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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