ESG: a roadmap of incoming EU regulations impacting asset managers

The European Commission’s Sustainable Finance Action Plan introduces a range of legislative measures that will impact asset management firms making available financial products within the EU.

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 and blog posts which explain the impact, scope and requirements of the various measures:

ESG regulation

Key dates

Overview of the various measures

EU Disclosure Regulation

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.

See our blog post for our thoughts on the applicability of the Disclosure Regulation to UK firms.

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EU Taxonomy Regulation

Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment and amend the Disclosure Regulation (known as the Taxonomy Regulation or Framework Regulation). It establishes a taxonomy, or glossary, for assessing whether certain economic activities are considered “sustainable” in accordance with one or more of six prescribed environmentally sustainable objectives. In time, the intention is to extend the taxonomy beyond purely environmentally sustainable objectives.

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ESG measures to amend the UCITS, AIFMD and MiFID rules

The suite of measures (the Delegated Acts), which will affect UCITS and AIF managers and MiFID investment firms (collectively, managers). The Delegated Acts are a further development of the European Commission’s Sustainable Finance Action Plan.

The 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.

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