ESA Joint Committee (EBA, ESMA, EIOPA) Q&A Database

Lack of data is a major challenge for FMPs. Although this hurdle seems less pressing when it comes to investments in undertakings that fall under the scope of the future CSRD, how could FMPs overcome

SFDR

What is to be reviewed by the third party? The internal process used to assess the Taxonomy-alignment or the data as such?

SFDR

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?

SFDR

Does the disclosure of the “minimum extent sustainable investments with an environmental objective aligned with the EU Taxonomy” have to be based on actual data or can it consist of a forecast calcula

SFDR

As of 1 January 2022, financial market participants that make available certain Article 8/9 products shall include information about the proportion of Taxonomy-aligned investments as a percentage of a

SFDR

How is it possible to practically apply the requirement to use “equivalent information” as referred to in Article 17(2)(b)?

SFDR

Are environmental controversies a suitable proxy for “Do No Significant Harm” (DNSH) for the purpose of “equivalent information” referred to in Article 17(2)(b) of the Delegated Regulation?

SFDR

Can the Taxonomy-alignment of assets owned by a fund, such as green bonds, be included in the calculation of the Taxonomy-alignment of the product where these assets are exchanged through derivatives,

SFDR

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

SFDR

Article 17 of the Delegated Regulation lays down the rules to compute the Taxonomy- alignment of a financial product. How should a financial product report on debt instruments which are not debt secur

SFDR

How should activities be counted that qualify as Taxonomy-aligned while at the same time contribute to another environmental and/or social objective?

SFDR

How should FMPs measure the positive contribution for sustainable investments and can they use the KPIs for taxonomy-alignment (Turnover, CapEx, OpEx)?

SFDR

When looking to carbon footprint major indices under the SFDR, we noticed that Enterprise Value Including Cash (EVIC) is expected as the denominator. Typically, Enterprise Value's main components are

SFDR

Do the rules for financial advisers also apply to financial advisers carrying non-advised sales (execution only)?

SFDR

Article 10 SFDR expressly mentions 'financial market participants' as the recipients of the obligations concerning the transparency of disclosures for financial products under Article 8 and 9 SFDR on

SFDR

Is it required to keep the same benchmark for the SRI and performance scenario calculations?

PRIIPs

Point 12 of Annex IV of the Delegated Regulation notes that where the objectives of the PRIIP make reference to a benchmark, that benchmark shall be used for the performance scenario calculations. How

PRIIPs

What is the meaning of indicating ‘the degree of freedom from the benchmark’ in Article 2a(d) of the Delegated Regulation?

PRIIPs

What is the meaning of ‘whether this approach includes or implies a reference to a benchmark’ in Article 2a(d) of the Delegated Regulation? A UCITS or AIF managed in reference to a benchmark index is

PRIIPs

What is the intended calculation for the “linear transformation” in point 7(c)(iv) iof Annex IV of the Delegated Regulation?

PRIIPs

If the benchmark is changed, how should the chart of past performance be displayed for the period preceding the change?

PRIIPs

Does Article 2(2a)(d) of the Delegated Regulation require a UCITS or AIF to provide a clear indication of whether it is actively or passively managed?

PRIIPs

Point 52(h) of Annex VI indicates that transaction costs are included in the ‘other ongoing costs’. What does this mean in terms of where transaction costs should be included in table 2 ‘Composition o

PRIIPs

Could you clarify for which intermediate holding periods should we show performance scenarios during the lifetime of a product? (E.g.: 1.1 years product, with remaining lifetime of 9 months). We belie

PRIIPs

In terms of the identification of sub intervals in point 7(a) of Annex IV of the Delegated Regulation are these all contained within in the time period defined in point 6 of Annex IV?

PRIIPs

The UCITS KIID framework introduced the concept of “Absolute Return Funds”. For these types of funds, there is no need to select an appropriate risk benchmark and the UCITS SRRI is determined in its e

PRIIPs

For the identification of additional shorter sub intervals in point 7(b) of Annex IV of the Delegated Regulation, does this mean only the sub intervals that are truncated by the end of the time period

PRIIPs

Can a fund with multiple share classes use the price history of an existing share class when a new share class is created rather than use the price history of a benchmark?

PRIIPs

What approach should be taken for Category 2 PRIIPs for which there is not an appropriate benchmark or proxy with sufficient historical data which meets the criteria set out in point 5 of Annex IV of

PRIIPs

What is the relationship between point 11 of Annex IV and Article 15 of the Delegated Regulation?

PRIIPs

Article 14(e) of the Delegated Regulation refers only to the publication of past performance of the underlying Category 2 investment options as required by Article 8(3) and not to the requirement in A

PRIIPs

For Category 2 PRIIPs, is it possible to use lower percentiles of the estimated distribution of outcomes as foreseen in point 24 of the Delegated Regulation?

PRIIPs

Regarding Article 8(3) of the Delegated Regulation: a) What is meant by "performance scenario calculations"? Is it necessary for the full calculations underlying each scenario to be published or just

PRIIPs

In the Delegated Regulation, the VEV for flexible funds is determined by taking the maximum of the three following options: 1. VEV of the returns of the share class self-history, 2. VEV of the returns

PRIIPs

If a UCITS, AIF or unit-linked insurance-based investment product does not yet have past performance data for one complete calendar year (and is not a UCITS or AIF which may provide simulated data for

PRIIPs

Where a UCITS, AIF or unit-linked insurance-based investment product refers to an index in its investment objectives and policy as a benchmark and will measure the performance against that index, but

PRIIPs

Point 15 of Annex IV of the Delegated Regulation states that for Category 2 PRIIPs for which there is not an appropriate benchmark with sufficient history, performance scenarios shall be calculated in

PRIIPs

Does the requirements in Articles 6(1) and 9 of the PRIIPs Regulation mean that past performance disclosed regarding a benchmark index should be consistent with past performance disclosure in other in

PRIIPs

What should be displayed in the bar chart for years when there is no data?

PRIIPs

Do the rules concerning the UCITS key investor information document (KIID) still apply?

PRIIPs

Is it possible to signpost to a glossary?

PRIIPs

Is it possible to show the complete name of the PRIIP when first mentioned in the KID and then simply refer to it as “the product” or “the Fund” thereafter?

PRIIPs

When several versions of a benchmark are available which differ in the approach taken to reinvestment of revenues, which version should be used in the past performance chart?

PRIIPs

Point 19 of Annex VIII of the Delegated Regulation states that “In the case of mergers referred to in Article 2(1)(p)(i) and (iii) of Directive 2009/65/EC, only the past performance of the receiving U

PRIIPs

Should existing retail investors within a UCITS umbrella fund, who switch or exchange units in one sub-fund for units in another, be provided with the KID for the sub-fund in which they are going into

PRIIPs

Is it possible to alter the prescribed wording in the KID template for OTC derivatives? It is recognised in point 6a of Annex III and point 12 of Annex V of the Delegated Regulation that some of the s

PRIIPs

Prior to 1 January 2023 is it possible to prepare a KID based on the new requirements in Commission Delegated Regulation (EU) 2021/2268, for example for a product launched between September and Decemb

PRIIPs

[Question deleted] (Revised 21 December 2022) 3. Which form and name should the ‘specific information on each underlying investment option’, referred to in Article 14 of the Delegated Regulation, tak

PRIIPs

Should individual KIDs be prepared for each class of units or shares within a UCITS or AIF?

PRIIPs

It should be clarified in Annex I of the Delegated Regulation, where the name of the group should be included and whether it should be shown in bold.

PRIIPs