Timeline

Key dates and developments

• The SFDR applied from 10 March 2021.
• Various elements of the SFDR are supplemented by detailed regulatory technical standards (Level 2 Regulatory Technical Standards, or RTS). 
• In April 2022, the European Commission adopted a Delegated Regulation with the final set of Regulatory Technical Standards that apply from 1 January 2023. The RTS set out the information to be given by firms in relation to the “principal adverse impacts” of their investment decisions. The annexes to the RTS also include mandatory templates for pre-contractual disclosures and periodic reporting for Article 8 and Article 9 products, including the additional information required by the Taxonomy Regulation.
• In October 2022, the European Commission adopted amendments to this Delegated Regulation that apply from 20 February 2023 to require financial market participants to disclose the extent to which their portfolios are exposed to Taxonomy-aligned fossil gas and nuclear-related activities, as set out in the Complementary Climate Delegated Act.
• The Taxonomy Regulation applied on 1 January 2022 in respect of the climate change mitigation and adaptation objectives and is expected to take effect from 1 January 2024 in respect of the other four environmental objectives. Products that are required to disclose the extent of their Taxonomy alignment have, therefore, been required to do so since 1 January 2022, even though there is very little data available that enables firms to do so. For the time being, many firms disclose zero alignment.
• The sustainability-related changes to firms’ obligations under AIFMD and MiFID applied on 1 August and 2 August 2022 respectively. Changes to the product governance obligations under MiFID applied on 22 November 2022.
• On 18 November 2022, ESMA published a consultation on the introduction of draft guidelines relating to the use of ESG or sustainability-related terms in funds’ names. The draft guidelines include proposals on: (i) the introduction of minimum quantitative thresholds and (ii) certain minimum safeguards for such funds.