ESG: a roadmap of incoming EU regulations impacting asset managers
We have produced a timeline which summarises the key dates proposed for implementing the Commission’s package of measures.
We have also prepared a series of notes which explain the impact, scope and requirements of the various measures:
Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (known as the Disclosure Regulation, ESG Regulation or SFDR), which is part of a broader legislative package under the European Commission’s Sustainable Finance Action Plan.
It requires firms to make strategic business and policy decisions regarding their approach to ESG which must be disclosed on the firm’s website and in pre-contractual and periodic disclosures. Although the focus of the Disclosure Regulation is the provision of information to investors, clients and other stakeholders, it is clear that the preparation of accurate and comprehensive information on ESG will necessitate significant system and control changes, and a material allocation of resource for many firms.
The suite of draft measures (the Draft Delegated Acts), which will affect UCITS and AIF managers and MiFID investment firms (collectively, managers). The Draft Delegated Acts are a further development of the European Commission’s Sustainable Finance Action Plan.
The Draft Delegated Acts follow the Disclosure Regulation (Regulation (EU) 2019/2088) and the Framework Regulation (Regulation (EU) 2020/852) (together, the Regulations), both already published in the Official Journal, and which apply to managers, and which prescribe certain website and investor-reporting disclosures about the firm’s approach to ESG.