EU Financial Regulatory Q&A Database

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

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

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

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

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

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

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

SFDR

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

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

Persons professionally arranging or executing transactions

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

Settlement fails

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

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)

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

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

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

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

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

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

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

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

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

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

Is it possible to signpost to a glossary?

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

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

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

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

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