ESA Joint Committee · sfdr-89 Final

Considering the provisions of the Delegated Regulation, a fund investing in real estate or infrastructure funds would be required to report on its Taxonomy-alignment in the same way than a non-financi

Regulation
SFDR
Answered
2022-11-17
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Question

Considering the provisions of the Delegated Regulation, a fund investing in real estate or infrastructure funds would be required to report on its Taxonomy-alignment in the same way than a non-financial undertaking, analysing the Taxonomy-alignment of its own economic activities. For instance, in the case of a real estate fund, it would report its own turnover, CapEx and Opex based on the criteria set out for activity 7.7 “Acquisition and ownership of buildings” set out in Delegated Regulation 2021/1239 supplementing TR. Yet, funds are not non-financial undertakings. In that regard, would it be possible for financial products to base their Taxonomy-alignment reporting in its pre-contractual disclosures on the market value of these real assets, and report alongside the other KPIs in the periodic disclosures?

Answer

Where a financial product reports on the Taxonomy-alignment of its investments in real estate or infrastructure assets, and not financial instruments, the financial product should be able to refer to the market value of these assets. All other rules to calculate the Taxonomy-alignment in Article 17 of the Delegated Regulation of an investment apply identically. Such reporting based on market values should only concern the real estate and infrastructure assets of the financial market participants, and not be extended to other kind of investments. It should be possible for a financial product to report on market values both in pre-contractual and periodic disclosures. For reasons of comparability, other KPIs, based on turnover, CapEx and OpEx should still be part of the periodic disclosures. So, despite the fact that the financial product investing in infrastructure / real assets may need a specific KPI, an investor should have the possibility to compare two financial products with each other.
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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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