EU Financial Regulatory Q&A Database

Reporting Templates

(EU) No 2015/2450 - templates for the submission of information to the supervisory authorities · Art. 35 of SII Directive

Reporting Templates

(EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision

Reporting Templates

(EU) No 2015/2450 - templates for the submission of information to the supervisory authorities · Art. 35 of SII Directive

Validations

(EU) 2020/852 - Taxonomy Regulation · Art. N/A

Reporting Templates

(EU) No 2015/2450 - templates for the submission of information to the supervisory authorities · Art. Annex II

Reporting Templates

(EU) No 2015/2450 - templates for the submission of information to the supervisory authorities · Art. Annex II

Reporting Templates

(EU) No 2015/2450 - templates for the submission of information to the supervisory authorities · Art. 35 of SII Directive

Reporting Templates

(EU) 2020/852 - Taxonomy Regulation · Art. N/A

Solvency Capital Requirement (SCR)

(EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII), (EU) No 2015/2011 - lists of regional governments & local authorities, exposures to be treated as to central government · Art. Article 1 of Commission Implementing Regulation (EU) 2015/2011; Article 180(2) of the Delegated Regulation (EU) 2015/35

Solvency Capital Requirement (SCR)

(EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII) · Art. 116

Reinsurance

(EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII) · Art. Article 42

Group Solvency Requirement

(EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII) · Art. 184; 335; 336(d);

Solvency Capital Requirement (SCR)

(EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII) · Art. 189

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

Article 9(3) SFDR sets out disclosure requirements for “a financial product, [which] has a reduction of carbon emissions as its objective”. Does this also apply if a financial product has “reduction o

SFDR

If a financial market participant with more than 500 employees does not market or make available any financial products as defined in Article 2(12) SFDR, does the financial market participant still ha

SFDR

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

SFDR

Should financial market participants disclose what share of PAI impacts have been estimated and what have been calculated on the basis of reported information?

SFDR

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

SFDR

In Table 1, indicator 16 (Investee countries subject to social violations), industry requests guidelines to ensure comparability, as there is a variety of approaches to this and lack of underlying dat

SFDR

On 21 April 2021 the European Commission proposed legislation to extend the non- financial reporting to enhance sustainability reporting while ensuring consistency with SFDR and the Taxonomy Regulatio

SFDR

Should the “information about the policies on the integration of sustainability risks in the investment decision-making process” of the financial market participant be restricted to investments affect

SFDR

A financial market participant manages a fund disclosing according to Article 8 or 9 SFDR. It manages 30% of this fund and delegates the management of the remaining 70%. Should the reported product le

SFDR

Are financial market participants allowed to define their own substantial contribution criteria for socially sustainable investments? Can a single financial market participant apply different interpre

SFDR

In Table 3, indicator 7.2 (Number of incidents of discrimination leading to sanctions), how should incidents that lead to sanctions be measured?

SFDR

It is common that many IORP voluntarily implement the OECD guidelines and therefore do voluntarily consider adverse impacts. Are they required to use the mandatory indicators?

SFDR

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

SFDR

An economic activity qualifies as environmentally sustainable where it contributes substantially to one or more of the six environmental objectives listed under Article 9 TR. During the period 1 Janua

SFDR

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

SFDR

Can taxonomy-aligned activities or PAI impacts from green bonds (or other specific project financing instruments like social bonds) be calculated for the projects they finance rather than taxonomy-ali

SFDR

Would it be possible to have a financial product disclosing under Article 8 SFDR that makes sustainable investments with environmental objectives which are not (yet) taxonomy aligned?

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

An Article 9 SFDR product with 100% non-Taxonomy compliant climate objectives, would still fill the Taxonomy sections with 0% and the social sustainable investment section with 0%? Please refer to the

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

What does “current value” mean?

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

How should "all investments" be understood? Gross asset value including cash, other assets, other liabilities? Or only actual investments, e.g., only private equity / private debt assets?

SFDR

How do you calculate indicator 8 (Emissions to water) from Table 1 (and similar indicators) where the explicit formula is not provided?

SFDR

Do you consider the provisions regarding "underlying investment options" e.g., Article 21 Delegated Regulation to be relevant for portfolio management products?

SFDR

Would a discretionary mandate that invests according to Investment Guidelines stipulated by the client be regarded as a financial product falling under Article 8 or Article 9 SFDR?

SFDR

In case a financial product referred to in Article 8 of Regulation (EU) 2019/2088 which promotes environmental characteristics does not commit in the pre-contractual disclosures to invest in any econo

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

For Art. 9 products that are partly taxonomy-aligned, should the disclosures refer to the technical screening criteria as indicators for the taxonomy-aligned part?

SFDR

Can the PAI indicators listed in the Annex 1, Table 1 Delegated Regulation be used as indicators to measure the attainment of environmental or social characteristics? See paragraphs 5-7 of the clarifi

SFDR

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

When it comes to entity-level disclosures in Article 4 should those disclosures relate only to financial products in scope of SFDR, or should those disclosures also relate to other types of instrument

SFDR

Annex I, Table I, indicator 13 (board gender diversity). Assume a company has 5 female board members and no male board members. The indicator is defined as follows: Average ratio of female to male boa

SFDR

If a financial market participant has to report on the consideration of ESG factors due to legally required information duties, such as under Directive (EU) 2016/2341, does this already qualify as "pr

SFDR

Can FMPs remove sections in the precontractual and periodic disclosure templates provided in Annex II to Annex V of the Delegated Regulation that are not deemed relevant for their financial product?

SFDR