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Adam Skinner

Kirkland & Ellis International LLP

Andy Burnett

Kirkland & Ellis International LLP

Daniel D’Ambrosio

Kirkland & Ellis International LLP

Deirdre Haugh

Kirkland & Ellis International LLP

James Roslington

Kirkland & Ellis International LLP

Julia Dixon

Kirkland & Ellis International LLP

Kate Stephenson

Kirkland & Ellis International LLP

Lisa Cawley

Kirkland & Ellis International LLP

Rhys Davies

Kirkland & Ellis International LLP

Thomas Woodhead

Kirkland & Ellis International LLP

3 Contributions by Kirkland & Ellis International LLP Experts

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]
PRACTICE NOTES
ARCHIVED: This Practice Note has been archived and is not maintained.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
EU Law
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
PRACTICE NOTES
ARCHIVED : This Practice Note has been archived and is not maintained.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
Financial Services
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]
PRACTICE NOTES
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
Financial Services
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