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

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

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

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

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

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 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

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

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

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

Should an FMP still disclose the indicators applicable to investments in “sovereigns and supranationals” and “real estate assets” if the FMP makes no investments in sovereigns, supranationals and real

SFDR

Calculation of Indicators 1 and 2 table 1 - Enterprise Value Question: For those indicators where Enterprise Value is used, how should we proceed if the Enterprise Value is negative?

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

In Annex I, Table 3, indicator 3 (Number of workdays lost to injuries, accidents, fatalities or illness of investee companies expressed as a weighted average) - may this be reported as absolute or rel

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

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

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

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

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

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

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

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

What does “current value” mean?

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

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

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

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

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

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

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

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

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

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

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

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

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