EU Financial Regulatory Q&A Database

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

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

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

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

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

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

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

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

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

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

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

Reporting Templates

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

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(3)

Other

Guidelines on reporting and public disclosure · Art. Directive 2014/65/EU

Own Funds (OF)

(EU) No 2017/1469 - standardised presentation format for the insurance product information document, Guidelines on classification of own funds · Art. N/A

Settlement fails

Central Securities Depositories Regulation (CSDR) Regulation (EU) No 909/2014- PTR- CSDR

Persons professionally arranging or executing transactions

Market Abuse Regulation (MAR) Regulation (EU) No 596/2014 - Market Intergrity

Own Funds (OF)

(EU) No 2015/35 - supplementing Dir 2009/138/EC - taking up & pursuit of the business of Insurance and Reinsurance (SII) · Art. Article 1 (item 46); Article 260 (item 2 and 3)

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

[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

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

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

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

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

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

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

How should actively-managed UCITS ETF be identified in the KID, and what information should be included in the “What is this product?” section of the KID? An actively-managed UCITS ETF should inform i

PRIIPs

How should UCITS ETFs be identified in the KID, and what information should be included in the “What is this product?” section of the KID? A UCITS ETF should use the term ‘UCITS ETF’ which identifies

PRIIPs

What type of information should be included in the “What is this product?” section of the KID of index-tracking UCITS and index-tracking leveraged UCITS? For index-tracking UCITS, the following inform

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 relationship between point 11 of Annex IV and Article 15 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

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

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

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

Regarding the methodologies for performance scenario described in Annex IV of the Delegated Regulation ((EU) 2021/2268) it is not clear what approach should be used to build performance scenarios for

PRIIPs

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

PRIIPs