Jurisdiction(s):
Ireland

September 2025 EU asset management and investment funds update: SFDR PAI disclosure practices and ESAs recommendations, ESMA risk report, CMU financing proposals, and CSDR T+1 settlement timeline

Published on: 10 October 2025

Published by a LexisNexis Ireland - Banking & Financial Services expert

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Article summary

Asset management & investment funds—EU & international developments—September 2025

The three European Supervisory Authorities (the European Banking Authority, the European Insurance and Occupational Pensions Authority and the European Securities and Markets Authority—ESAs) annual report on voluntary PAIs disclosures under SFDR

The ESAs have released their fourth annual report on PAI disclosures under the SFDR. It concludes that financial market participants are supplying more comprehensive and higher quality disclosures, with large multinational groups most advanced. Smaller firms, by contrast, frequently blend generic environmental, social and governance or promotional material with SFDR content, leaving it unclear whether PAIs are being taken into account. The report also observes that more FMPs now provide entity‑level information in clearly labelled sustainability or SFDR sections on their websites, improving transparency and ease of access. It outlines examples of good and below‑average disclosure practices and offers recommendations to national competent authorities and to the European Commission in advance of the SFDR review.

Entity level disclosures

Access:

good: disclosures kept in the same place as the previous year, reachable via a direct link or keyword search
below average: information dispersed across the website, difficult to find from the homepage, with non‑intuitive links to the section

Clarity:

...

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