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Commission definition

What does Commission mean? In legal practice, a commission is a payment, usually percentage‑based, made to an agent, broker or introducer for securing business or facilitating a transaction. Under UK bribery law, the Bribery Act 2010 (England & Wales, Scotland and Northern Ireland) does not define commission, but criminalises offering, promising, giving, requesting or receiving a financial or other advantage to induce or reward improper performance. A commission may constitute such an advantage depending on intent, knowledge and context; not every commission is a bribe. Transparent, proportionate, contractual commissions for genuine services are generally lawful, whereas concealed or disproportionate payments, particularly to public...

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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
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ARCHIVED : This Practice Note has been archived and is not maintained.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...

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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....

Rhys Davies
Rhys Davies

Rhys Davies is a partner in the ESG & Impact Practice Group in the London office of Kirkland & Ellis International LLP. Rhys has more than 15 years of ESG experience, including advising private equity firms, public companies and project sponsors in relation to the design and implementation of ESG strategies across a range of sectors, including energy and natural resources, infrastructure, real estate and technology.Rhys' experience includes advising on sustainable finance disclosures (including pursuant to the EU Sustainable Finance Disclosure Regulation), green taxonomies, sustainability reporting, climate change, biodiversity loss, human rights and responsible business practices. He has assisted clients to develop and review ESG-related governance measures, policies, strategies, metrics and disclosures in a number of jurisdictions under both mandatory and voluntary frameworks.Rhys also has broad environmental and social regulatory experience, including in relation to environmental impact assessment, emissions licensing,...

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....

Andy Burnett
Andy Burnett

Andy is an associate in the London office of Kirkland & Ellis International LLP and a member of the Firm’s ESG & Impact Practice Group, which advises private equity firms, corporations, project sponsors and lenders on complex and evolving legal issues relating to environmental, social and governance (ESG) and climate-related regulatory requirements, investor demands, strategic opportunities, and voluntary reporting frameworks and coalitions.He advises across the full range of ESG legal services, including ESG-linked private and public market financings, fund formation mandates, and corporate M&A transactions. He has advised funds on the application of the Sustainable Finance Disclosure Regulation to the categorization, strategy and operational risk and opportunity management programs of their alternative investment funds. As part of this work, he has helped establish market-leading ESG-driven Article 9 funds and is particularly interested in the development of impact...

Web page updated on 21/05/2026

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