Financial Services Ireland


Sustainable Finance Disclosure Regulation (SFDR): March 2021 and beyond

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New disclosure requirements for financial market participants and financial advisers under the Sustainable Finance Disclosure Regulation (SFDR)

The Sustainable Finance Disclosure Regulation (SFDR), the first EU Action Plan for sustainable growth regulation, came into force on 10 March 2021. It lays down sustainability disclosure obligations for financial market participants and financial advisors towards end-investors. It does so in relation to the integration of sustainability risks by financial market participants and financial advisers in all investment processes and for financial products that pursue the objective of sustainable investments.

Our latest paper, which you can download below, sets out key requirements for asset managers, insurers and banks and aims to provide answers to the following questions:

  • Does the SFDR also apply to financial market participants who don’t have environmental or social products?
  • To what extent do insurance undertakings and institutions for occupational retirement provision (IORPs) fall under the scope of SFDR?
  • How should products falling under the scope of SFDR be classified and what are the requirements which apply with regard to their ESG approach?
  • What are the disclosure requirements at entity and product level?
  • What are the key regulatory milestones?

SFDR impacts financial market participants and financial advisors, including:

  • Insurance companies and insurance intermediaries
  • Institutions for occupational retirement provision (IORPs)
  • Investment firms and credit institutions providing portfolio management or investment advice
  • Alternative Investment Fund Managers (AIFMs)
  • Undertakings for collective investment in transferable
  • Securities (UCITS management companies)

Affected financial products under the SFDR include:

  • Insurance-based investment products (IBIPs)
  • Pension products and pension schemes
  • Pan-European personal pension products (PEPPs)
  • Alternative investment funds (AIFs)
  • Portfolios managed by an investment firm in accordance with MiFID II

Find out more in our report and don’t hesitate to reach out if you have a question.

Thought Leaders

James Maher

Insurance, Sector Leader

Fidelma Clarke

FS Partner, Sustainable Finance Consulting