EU Financial Regulatory Q&A Database

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

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

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

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

SFDR

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

SFDR

How can a financial product disclosing under Article 8 SFDR assess that good governance is effectively considered? Is a reference to the UN Global compact sufficient or should there be an alignment wi

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

Is it possible to comply with Article 6 SFDR by just saying that sustainability risks are not being integrated and not taken into account yet, or does Article 6 SFDR mean that sustainability risks sho

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

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

How is the envisaged product classification in case of a multi-option product (MOP) that comprises only one investment option that (partially) invests in line with the Taxonomy Regulation? Would the e

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

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

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

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

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

Example on how to calculate the value on an Indicator where an FMP has 2 Financial Products (FP) with 2 investments (Inv) each.

SFDR

Product disclosures as presented in art. 10 SFDR and art.31 to 57 Delegated Regulation: Can EIOPA provides more clarity on the fact, as it wasn’t specified in the Delegated Regulation, that website di

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

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

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

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

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

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

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

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

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

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

CO2 emissions for Company A are 5000 tonnes. If a financial market participant holds 10% of the company the first 6 months of the reference period for reporting and 0% the remaining 6 months of the pe

SFDR

Annex I, Table 2, indicator 6 (water usage and recycling). How should one calculate the PAI in table 2 for indicators 6.1 (Average amount of water consumed and reclaimed by the investee companies (in

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

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

What does “current value” mean?

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

In Annex I, Table 2, indicator 18 (GHG emissions), do we take the % of ownership into account when calculating the total GHG emissions (i.e. should GHG emissions be calculated as sum of all GHG emissi

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 the objective-aligned index designated as a reference benchmark under Article 9(1) SFDR, i.e. the “designated index” referred to in 9(1)(a) or 9(1)(b), be a broad market index?

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

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

The question relates to the separation of asset class in Annex I, Table 1, indicator 4 (Exposure to companies active in the fossil fuel sector) and 17 (Exposure to fossil fuels through real estate ass

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

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

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

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

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

Hybrid products and Article 22 Delegated Regulation: Can EIOPA provide more clarity on the use of Article 22 of the Delegated Regulation? Can this article be used for the guaranteed part of a hybrid p

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

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