Revathi Raghavan
Reva has extensive experience in advising sponsors on the regulatory aspects of fund formation and the regulations governing fund sponsors across all major alternative investment strategies. In particular, Reva advises on a broad range of EU and UK financial services regulations, including the UK Senior Managers and Certification Regime (SMCR), the Investment Firms Prudential Regime (IFPR), the UK Market Abuse Regulation (MAR), the EU Markets in Financial Instruments Directive II (MiFID II), the Alternative Investment Fund Managers Directive (AIFMD), SFDR, and the Taxonomy Regulation.
Practice Area
Panel
- Contributing Author
Experience
- Allen & Overy LLP (2009 - 2019)
Education
- The George Washington University Law School (2008)
- NALSAR University of Law (2007)
3 Contributions by Revathi Raghavan
![EU SFDR 2022 Regulatory Technical Standards: FAQs on Article 8/9 classification, PAI/PASI data and templates, periodic disclosures, Taxonomy alignment, exclusions, and non-EU AIFM entity-level obligations [Archived]](images/default-source/pa-pool/9.tmb-small.jpg)
PRACTICE NOTES
EU SFDR 2022 Regulatory Technical Standards: FAQs on Article 8/9 classification, PAI/PASI data and templates, periodic disclosures, Taxonomy alignment, exclusions, and non-EU AIFM entity-level obligations [Archived]
ARCHIVED: This Practice Note has been archived and is not maintained.
These Q&As respond to the most common queries on the EU Sustainable Finance Disclosure Regulation (EU SFDR) (Regulation (EU) 2019/2088, as amended by Regulation (EU) 2020/852) regulatory technical standards (RTS). They address, among other areas, product categorisation; Article 8 features; principal adverse impact (PAI) data gathering; reliance on third-party information; human rights due diligence, and the effect on non-EU managers. On 6 April 2022, the Commission approved the final Regulatory Technical Standards (RTS) that supplement the EU Sustainable Finance Disclosure Regulation (EU SFDR) (Regulation (EU) 2019/2088, as amended by the EU Taxonomy Regulation (EU) 2020/852) together with the Annexes. EU SFDR imposes substantial environmental, social and governance (ESG) disclosure duties on asset managers promoting funds within the EU. The RTS set out compulsory website, pre-contractual and periodic reporting templates for financial market participants and relevant financial products. For further detail, see Commission publishes adopted RTS containing disclosure rules on sustainable investments under EU SFDR, LNB News 06/04/2022 92. Below we respond to several of the most frequently raised questions regarding EU SFDR, reflecting the final RTS adopted in 2022. Implementation of the EU SFDR has been carried out by...
EU Law
PRACTICE NOTES
EU SFDR II review: consultations on RTS, PAI, Articles 8/9 and product labelling; ESMA fund names and UK FCA SDR—archived FAQ for UK lawyers
ARCHIVED : This Practice Note has been archived and is not maintained.
These Q&As address many of the most common queries on consultations relating to the EU Sustainable Finance Disclosure Regulation (SFDR), covering proposed adjustments to the delegated regulations and the SFDR review (SFDR II).
There are a number of ongoing consultations on SFDR—are material changes expected?
In 2023, numerous consultations on Regulation (EU) 2019/2088 (EU SFDR) took place, including an assessment of the SFDR Delegated Regulation (which contains the regulatory technical standards) (Commission Delegated Regulation (EU) 2022/1288, as amended) concentrating on revisions to the principal adverse impacts (PAI) regime and specific financial product disclosures, alongside a targeted and public consultation seeking feedback on amendments to the EU SFDR itself (EU SFDR II).
Possible outcomes may feature updated templates, stricter obligations for data collection and diligence on negative externalities, and potentially changes to the Article 8 and Article 9 classifications. Certain private equity industry bodies are proposing a voluntary labelling framework to sit alongside mandatory disclosures, taking inspiration from the UK Financial Conduct Authority (FCA) proposals. For more information, see Practice Note: Sustainable finance and ESG in the UK financial sector—FCA's priority areas—Trust:...
Financial Services
PRACTICE NOTES
EU SFDR RTS: FAQs on Article 8/9 criteria, PAI/PASI data, sustainable investment diligence, exclusions, third‑party data and non‑EU AIFM entity‑level disclosures [Archived]
ARCHIVED : This Practice Note has been archived and is not maintained.
These Q&As address many of the most common queries on the EU Sustainable Finance Disclosure Regulation (EU SFDR) regulatory technical standards (RTS) (Regulation (EU) 2019/2088, as amended by Regulation (EU) 2020/852).
Product categorisation
Article 8 features
Principal adverse impacts (PAI) data gathering
Reliance on third-party data
Human rights due diligence
Implications for non-EU managers
On 6 April 2022, the European Commission signed off the final RTS and their Annexes supplementing the EU SFDR (Regulation (EU) 2019/2088, as amended by the EU Taxonomy Regulation (EU) 2020/852).
EU SFDR places substantial ESG transparency duties on asset managers offering funds in the EU.
The RTS set out compulsory website, pre-contractual and periodic reporting templates for financial market participants and covered financial products.
For further details, see Commission publishes adopted RTS containing disclosure rules on sustainable investments under EU SFDR, LNB News 06/04/2022 92.
Below we respond to frequently posed questions on EU SFDR informed by the 2022 final RTS.
EU SFDR has been brought in through phased requirements supplemented...
Financial Services
If you expected to see yourself on this page, click here.
