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)
⚠

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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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