Once you have reported on your Article 5-6 TR financial product, should your pre- contractual information still be a minimum ambition or the actual achieved level of taxonomy aligned investments?

Subject to the sectoral rules governing pre-contractual disclosures in Article 6(3) SFDR and any relevant contractual commitments, the disclosure of the minimum extent of Taxonomy-alignment of investments of the financial product is a commitment which should be met at all times (this also applies to (1) the disclosure of the minimum proportion of the investments of the financial product used to meet the environmental or social characteristics or sustainable investment objective(s) of the financial product and (2) to sustainable investments). Therefore, the pre-contractual disclosure should not include “targets” for Taxonomy-alignment, nor the actual achieved level of Taxonomy- aligned investments, but only the minimum proportion which the financial product commits to meet. The periodic disclosures are intended to appropriately reflect the Taxonomy-aligned investments achieved by the product, including where the actual Taxonomy-alignment is higher than the minimum proportion. Furthermore, for new financial products the reference in Article 17 of the Delegated Regulation of the calculation of the Taxonomy-alignment of the aggregated investments should be understood as “expected investments” in the context of the disclosure of the binding commitment to the investor about the financial product’s Taxonomy-alignment of investments.