LINARI LAW

SFDR 2.0: Key Changes Ahead for Luxembourg Funds and Asset Managers

The European Commission’s ongoing review of the Sustainable Finance Disclosure Regulation (SFDR) has led to the anticipated release of SFDR 2.0, bringing significant changes for Luxembourg-based asset managers, fund managers, and financial institutions, and notably:

New Product Categorization

SFDR 2.0 will introduce a revised product categorization system, with clearer definitions. The current Article 6 / 8 / 9 structure will be replaced by new categories, such as “Transition-related objectives” (Article 7), “Integration of sustainability factors” (Article 8), and “Sustainability-related objectives” (Article 9).

Simplification of Entity-Level Disclosures

The revised framework will ease some of the current burdens by removing the requirement for entity-level Principal Adverse Impact (PAI) disclosures and remuneration reporting.

Enhanced Data and Reporting Standards

With SFDR 2.0, 70% of assets must meet the stated sustainability objectives to qualify under the respective categories. New mandatory exclusions for sectors such as fossil fuel expansion and tobacco will apply.

Improved Alignment with EU Sustainability Regulations

SFDR 2.0 aims for greater coordination with the EU Taxonomy and other sustainability regulations. The new rules will harmonize disclosure requirements across multiple sustainability frameworks.

While SFDR 2.0 is expected to come into force by 2027/2028, Luxembourg-based funds will need to prepare for dual reporting in the interim.

For further details on how these changes will impact your Luxembourg funds, feel free to reach out. We can assist with tailored guidance and compliance strategies to help you stay ahead.

 

 

Photo – Rosc Art

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