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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]

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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...

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Ruth Knox
Ruth Knox

Ruth Knox is a partner in the Corporate Department and chair of the ESG & Sustainable Finance practice at Paul Hastings and is based in the firm’s London office. Ruth advises some of the world’s most sophisticated private equity firms, corporations and project sponsors and lenders on complex and evolving legal issues relating to environmental, social and governance and climate-related regulatory requirements, investor demands, strategic opportunities (including transition strategies) and voluntary reporting frameworks and coalitions. She is an environment and climate change legal authority. Ruth’s practice focuses on counseling clients on the management, mitigation and maximization of ESG risks and opportunities, respectively. She has spent more than a decade advising on ESG regulations and soft law standards, including the EU Sustainable Finance package, the Corporate Sustainability Reporting Directive and the Task Force on Climate-related Financial Disclosure (TCFD) standard. She provides commercial,...

Daniel D’Ambrosio
Daniel D’Ambrosio

Dan’s practice focuses on counselling clients on ESG and sustainability matters across a range of corporate, fund formation and sustainable finance transactions, regulatory compliance matters and complex ESG disputes and crises. Dan has supported private equity clients globally to navigate emerging ESG regulatory frameworks such as SFDR and EU Taxonomy and translate requirements into strategy, governance, policies and risk management processes as well as downstream M&A transactions.Dan has significant experience advising private equity clients, corporations, project sponsors and lenders on human rights matters and compliance with international frameworks such as the OECD Guidelines, UN Guiding Principles on Business and Human Rights, the Equator Principles and the IFC Performance Standards....

Lisa Cawley
Lisa Cawley

Kirkland partner Lisa Cawley has extensive experience in financial services regulation, gained over more than 20 years. Lisa regularly advises on: governance and other compliance arrangements to comply with changes in EU / UK financial services regulation, including MiFID II and PRIIPS; the establishment of new investment, banking and insurance businesses in the UK, and applications for FCA authorisation; and the establishment of compliance processes for investment businesses, and ongoing regulatory advice....

Julia Dixon
Julia Dixon

Kirkland partner Julia Dixon is an experienced financial services regulatory partner who advises clients on contentious regulatory investigations and proceedings, non-contentious advisory matters and transformational projects and transactions. Julia regularly advises on authorisation, licensing and permission requirements, the establishment of compliance programmes and arrangements for monitoring and testing, and regulatory issues and compliance with UK/EU regulation, including the promotion and marketing of financial products, conduct of business, conflicts of interest, client money and assets, market abuse and insider dealing....

Revathi Raghavan
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....

Web page updated on 21/05/2026

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