ESA Joint Committee · sfdr-9 Final

Do the ESAs have a view on how to incorporate short positions within the PAI indicators – should they be excluded, by being deducted from the PAI indicator calculations where the shorts relate to a br

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

Do the ESAs have a view on how to incorporate short positions within the PAI indicators – should they be excluded, by being deducted from the PAI indicator calculations where the shorts relate to a brown asset, or should they be added for each of the PAI indicators?

Answer

The rules do not specify separately any particular instruction for the disclosure of short positions with regard to the principal adverse impact disclosures in Annex I of the Delegated Regulation. The ESAs are of the view that publishing short positions separately from the main calculation would not help the comprehensibility of the PAI disclosures. The calculations for short positions should apply the methodology used to calculate net short positions laid down in Article 3(4) and (5) of Regulation (EU) No 236/2012 of the European Parliament and of the Council. The principal adverse impacts of long and short positions should also be netted accordingly at the level of the individual counterpart (investee undertaking, sovereign, supranational, real estate asset), but without going below zero.
View original on ESA Joint Committee (EBA, ESMA, EIOPA) ↗

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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