SFDR: What is article 6, 8 & 9? (2024)

The EU’s Sustainable Finance Disclosure Regulation (SFDR) requires asset managers to classify their funds as either an article 6, 8 or 9 fund depending on their level of sustainability –but what does this mean, exactly?

In this blog, we have gathered everything you need to know about articles 6, 8 and 9. What articles are you affected by? How do you comply? And what is needed for a fund to be classified ESG? Let’s have a look:

What is the SFDR?

SFDR is a part of the EU’s Financing Sustainable Growth Action Plan and was established to reorientate capital flow towards sustainable finance. SFDR requires asset managers and other financial market participants to provide transparency on sustainability and imposes mandatory ESG disclosure obligations.

SFDR article 6, 8 & 9: Disclosure requirements

The SFDR sets out mandatory ESG disclosures requirements for asset managers to comply with. The aim is to create more transparency into their investment strategies and prevent greenwashing and claims that products are sustainable when they are in reality not.

According to the SFDR’s classification system, a fund will either be classified as an article 6,8 or 9 fund –depending on their characteristics and level of sustainability:

Article 6: Funds without a sustainability scope

Article 8: Funds that promote environmental or social characteristics (light green)

Article 9: Funds that have sustainable investment as their objective (dark green)

In essence, article 6 requires asset managers to disclose the integration of sustainability risks in their funds– regardless if the fund is promoted as ESG or not. Investments promoted as ESG, however, are required to classify as being either an article 8 or 9 fund, depending on which classification requirements their financial products meet. Many are referring to article 8 funds as “light green” and article 9 as “dark green” since the requirements are higher to be labeled an article 9 fund. Just to make it extra crisp, let’s dive even deeper into what the different articles imply and what you have to do to meet the requirements.

SFDR: What is article 6, 8 & 9? (1)

What is SFDR article 6?

Article 6: Transparency of the integration of sustainability risks requires the following:

“Financial market participants shall include descriptions of the following in pre-contractual disclosures:

  • The manner in which sustainability risks are integrated into their investment decisions; and

  • The results of the assessment of the likely impacts of sustainability risks on the returns of the financial products they make available.

Where financial market participants deem sustainability risks not to be relevant, the descriptions referred to in the first subparagraph shall include a clear and concise explanation of the reasons therefore.”

This means that provisions for the above disclosures must be included already in the fund’s prospectus. If sustainability risks are considered to be relevant for a fund, assets managers are required to:

  • Declare that they have integrated sustainability risks into the investments decisions;

  • Develop a process to assess and identify the most significant risks

  • Have a disclosure policy in place that mitigate and acts on risks;

  • Describe how it will be achieved and track the implementation and results

And remember, funds don’t have to be classified as ESG or Green for this article to apply, and if a fund deems sustainability risks not to be relevant, it must clearly be stated and rationalized according to the article.

What is SFDR article 8?

For a fund to comply with article 8: Transparency of the promotion of environmental or social characteristics in pre‐contractual disclosures requires the following:

“Where a financial product promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices, the information to be disclosed pursuant to article 6 shall include the following:

  • Information on how those characteristics are met;

  • If an index has been designated as a reference benchmark, information on whether and how this index is consistent with those characteristics.”

Financial market participants shall include in the information to be disclosed pursuant to article 6(1) and (3) an indication of where the methodology used for the calculation of the index referred to in paragraph 1 of this article is to be found.

So, article 8 applies to funds promoting environmental and social objectives and which take more into account than just sustainability risks as required by article 6.

However, article 8 funds don’t have ESG objectives or core objectives – as required for becoming labeled an article 9 fund.

What is SFDR article 9?

For a fund to comply with article 9: Transparency of sustainable investments in pre‐contractual disclosures requires the following:

“Where a financial product has sustainable investment as its objective and an index has been designated as a reference benchmark, the information to be disclosed pursuant to article 6 shall be accompanied by the following:

  • Information on how the designated index is aligned with that objective;
  • An explanation as to why and how the designated index aligned with that objective differs from a broad market index.”

Compared to article 8 funds, which should promote environmental or social characteristics and have good governance practices, article 9 funds should make a positive impact on society or the environment through sustainable investment and have a non-financial objective at the core of their offering. Both article 8 and article 9 funds will be considered ESG aligned, only that the latter one is for even further forerunners in sustainability, hence the light green and dark green reference.

How the EU Taxonomy links to SFDR

The EU Taxonomy is a classification system for environmentally sustainable economic activities and is integrated into the SFDR – specifically article 8 or 9 as these cover environmentally and or socially sustainable investments.

For both articles, a fund needs to disclose information about the proportion of Taxonomy alignment. Alignment should be expressed as percentage in turnover, capex and opex and also separated per transitional and enabling activities.

SFDR: What is article 6, 8 & 9? (2)

Integrate your ESG risk analysis in Worldfavor

If you need help to get going with your SFDR reporting and follow-up process, then we got the solution for you! Worldfavor’s Sustainable Investment is a finance solution that allows you to collect, aggregate and analyze all needed data in order to comply with the SFDR and report on time. Whether you’re directly or indirectly affected by the SFDR framework, Worldfavor’s experts can help you to comply with the reporting and disclosure requirements.

Download our guide Align and report on SFDR with Worldfavor and learn about how the SFDR process works and the benefits of using a sustainability platform to complete your report.

SFDR: What is article 6, 8 & 9? (3)

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  • The state of sustainable investments – key takeaways

  • 6 tips to get to know the sustainable finance disclosure regulation (SFDR)
  • What is SFDR, EU’s sustainable finance disclosure regulation?

Sustainable Investments

SFDR: What is article 6, 8 & 9? (2024)

FAQs

What is Article 8 and 9 SFDR? ›

These are: Article 9 funds: those funds that specifically have sustainable goals as their objective (for example investing in companies whose goal it is to reduce carbon emissions). Article 8 funds: those funds that promote E or S characteristics but do not have them as the overarching objective.

What is an Article 6 Sfdr fund? ›

What is an Article 6 product under SFDR? Article 6 is the default classification for funds, and the one most appropriate for those with no ESG focus. This means funds that neither have a sustainable investment objective, nor do they embrace investment in assets with environmental or social benefits.

What is SFDR Article 9? ›

An Article 9 Fund under SFDR is defined as “a Fund that has sustainable investment as its objective or a reduction in carbon emissions as its objective.” There are a number of different requirements for Funds that promote a sustainable investment objective.

What is an Article 8 Sfdr fund? ›

An Article 8 Fund under SFDR is defined as “a Fund which promotes, among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments are made follow good governance practices.”

What is the difference between Article 8 and Article 9? ›

Article 8 products promote environmental or social characteristics in the pursuit of other financial objectives. Article 9 products seek to make a positive impact on society or the environment through sustainable investment and have a non-financial objective at the core of their offering.

How many article 8 and 9 funds are there? ›

There were 6,862 funds classified as Art. 8 and 898 as Art. 9 as of the end of March. Flows into the most sustainability-focused funds also materialized despite strong outperformance from energy stocks, an industry that may be under-represented in many 'green' funds.

What is Article 6 ESG? ›

Article 6 covers funds which do not integrate any kind of sustainability into the investment process and could include stocks currently excluded by ESG funds such as tobacco companies or thermal coal producers.

What are the Sfdr classifications? ›

SFDR product classifications fall under 3 categories: Article 8, Article 9 and 'Other. ' Article 8 and Article 9 products consider sustainability in a binding way. In addition, Article 8 products promote social and or environmental characteristics and Article 9 products have a sustainable objective.

What funds does Sfdr apply to? ›

The SFDR applies to financial market participants and financial advisors within the EU. This includes asset managers, institutional investors, insurance companies, and pension funds, among others.

What is SFDR and EU taxonomy? ›

The EU Taxonomy is the fundamental cornerstone of a suite of regulation to be launched by the EU to improve and standardise sustainability reporting. In particular, the Taxonomy will support the Sustainable Finance Disclosure Regulation (SFDR) and the upcoming Corporate Sustainability Reporting Directive (CSRD).

What is a dark green fund? ›

Article 9 (Dark Green) Fund – A fund with sustainable investment as its sole objective. Sustainable investment under the SFDR is defined as an investment that: Contributes to an environmental objective in assisting that objective. Contributes to tackling inequality or social conflict/issues.

What is principal adverse impact? ›

Principal Adverse Impacts (PAIs) – Negative, material, or potentially material effects on sustainability factors that result from, worsen, or are directly related to investment choices or advice performed by a legal entity. Examples include GHG emissions and carbon footprint.

What is SFDR EU regulation? ›

In March 2021, the European Union's Sustainable Finance Disclosure Regulation (SFDR) came into force. The SFDR is designed to help institutional asset owners and retail clients understand, compare, and monitor the sustainability characteristics of investment funds by standardizing sustainability disclosures.

What does light green FP mean in the context of SFDR? ›

Light Green Fund statement: “This financial product promotes environmental or social characteristics, but does not have as its objective a sustainable investment.” No significant harm to the sustainable investment objective.

What is ESG article? ›

ESG stands for environmental, social and governance. These are called pillars in ESG frameworks and represent the 3 main topic areas that companies are expected to report in. The goal of ESG is to capture all the non-financial risks and opportunities inherent to a company's day to day activities.

What does Article 9 say? ›

Article 9 protects your right to freedom of thought, belief and religion. It includes the right to change your religion or beliefs at any time. You also have the right to put your thoughts and beliefs into action.

What is investment ESG? ›

ESG Investing (also known as “socially responsible investing,” “impact investing,” and “sustainable investing”) refers to investing which prioritizes optimal environmental, social, and governance (ESG) factors or outcomes.

What is ESG business? ›

Environmental, social, and governance (ESG) investing refers to a set of standards for a company's behavior used by socially conscious investors to screen potential investments. Environmental criteria consider how a company safeguards the environment, including corporate policies addressing climate change, for example.

What is a Ucits scheme? ›

UCITS stands for Undertakings for the Collective Investment in Transferable Securities. This refers to a regulatory framework that allows for the sale of cross-Europe mutual funds. UCITS funds are perceived as safe and well-regulated investments and are popular among many investors looking to invest across Europe.

What are sustainability risks Sfdr? ›

Sustainability risk in the SFDR is defined as: “An environmental, social, or governance event, or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment arising from an adverse sustainability impact.”

What are pre contractual disclosures? ›

Pre-contractual disclosure means the sharing of material information about the franchise opportunity prior to the formalisation of the legal relationship. Its purpose is to ensure that the sales process is grounded in fact and that the parties can make a sober and objective assessment of the commercial opportunity.

Is Sfdr compulsory? ›

While the SFDR does not make it compulsory to provide training to employees on the new disclosure regime, it is inevitable that relevant persons (for example, client-facing financial advisers and senior managers with ultimate responsibility for compliance with the SFDR) will require, and should be provided with, ...

What does SFDR mean for companies? ›

The Sustainable Finance Disclosure Regulation (SFDR) is an EU initiative that requires financial market participants operating in the EU, to disclose the various sustainability risks associated with their investments and products, as well as to disclose their policies relating to these risks.

What is the full form of SFDR? ›

The Sustainable Finance Disclosure Regulation (SFDR) is a European regulation introduced to improve transparency in the market for sustainable investment products, to prevent greenwashing and to increase transparency around sustainability claims made by financial market participants.

Is Sfdr only for EU? ›

No. SFDR does not apply to a non-EU AIFM which sells funds in the EU in response to reverse enquiry only.

Who needs to report under Sfdr? ›

SFDR Level 1 requires financial institutions within the EU—or those marketing to EU investors—to make principles-based disclosures on ESG-related activity. Firms must report not only on the sectors they invest in, but also on their portfolio companies. Further, SFDR disclosures are not limited to marketing materials.

Who has to report under Sfdr? ›

Product-level disclosure

Under the SFDR, financial market participants and financial advisers are required to disclose product information related to sustainability for both environmental, social, and governance (ESG)-related products and non-ESG products.

What is the difference between SFDR and NFRD? ›

Hence, for investors NFRD is mostly relevant because it stipulates how investee companies report ESG data. SFDR, by contrast, most concerns financial market actors and ensures transparency about how these report on sustainability risks to their audiences (e.g., retail investors).

What is the EU ESG Taxonomy? ›

The EU taxonomy is a classification system, establishing a list of environmentally sustainable economic activities. It could play an important role helping the EU scale up sustainable investment and implement the European green deal.

What does Taxonomy aligned mean? ›

‍Aligned activity/Alignment: an eligible economic activity that is making a substantial contribution to at least one of the climate and environmental objectives, while also doing no significant harm to the remaining objectives and meeting minimum standards on human rights and labour standards.

Are green funds green? ›

Green funds are mutual funds or other types of investment vehicles that promote socially and environmentally conscious policies and business practices. Green funds might invest in companies engaged in green transportation, alternative energy, and sustainable living.

What is Pasi reporting? ›

The Principal Adverse Sustainability Indicators (“PASI”) detailed in the SFDR include a range of mandatory and voluntary indicators that FMPs are either required or may choose to report. In order to comply with the PASI requirements, FMPs will need to obtain ESG footprint data from their investee companies.

Why green fund is important? ›

Green financing is to increase level of financial flows (from banking, micro-credit, insurance and investment) from the public, private and not-for-profit sectors to sustainable development priorities.

What are the mandatory Pai indicators? ›

List of PAI indicators:
  • GHG emissions (Scope 1, 2, 3 and total)
  • Carbon footprint.
  • GHG intensity of investee companies.
  • Exposure to companies active in the fossil fuel sector.
  • Share of non-renewable energy consumption and production.
  • Energy consumption intensity per high impact climate sector.

How many principal adverse impacts are there? ›

The Principal Adverse Impacts, or PAIs, are measured by an assortment of 14 mandatory corporate indicators, with two additional indicators for sovereigns and two real-estate specific indicators.

Is Pai part of SFDR? ›

Principal Adverse Impact (PAI) is a key concept in the EU's Sustainable Finance Disclosure Regulation (SFDR), one of the EU Action Plan on Sustainable Finance's landmark regulations.

Why is SFDR important? ›

SFDR is the first regulation set by the EU which aims to reorientate capital flow towards sustainable finance. SFDR is inserted to provide transparency on sustainability within the financial market and thereby prevent greenwashing.

What is the EU taxonomy and how will it work in practice? ›

The EU Taxonomy aims to provide clarity to investors and protection against “greenwashing”. Once companies begin disclosing their alignment with the technical screening criteria, it will provide detailed information on the actual environmental impact and sustainable performance of economic activities.

What are the 3 pillars of ESG? ›

The three pillars of ESG are:
  • Environmental – this has to do with an organisation's impact on the planet.
  • Social – this has to do with the impact an organisation has on people, including staff and customers and the community.
  • Governance – this has to do with how an organisation is governed. Is it governed transparently?
14 Jul 2022

What are the 3 principle of sustainability? ›

The principles of sustainability are the foundations of what this concept represents. Therefore, sustainability is made up of three pillars: the economy, society, and the environment. These principles are also informally used as profit, people and planet.

What is ESG in simple words? ›

Environmental, social and governance (ESG) is a term used to represent an organization's corporate financial interests that focus mainly on sustainable and ethical impacts. Capital markets use ESG to evaluate organizations and determine future financial performance.

What does SFDR stand for? ›

Spurious-free dynamic range (SFDR) is the strength ratio of the fundamental signal to the strongest spurious signal in the output. It is also defined as a measure used to specify analog-to-digital and digital-to-analog converters (ADCs and DACs, respectively) and radio receivers.

What is SFDR ESG? ›

SFDR is a new regulation requiring financial service providers and owners of financial products to assess and disclose environmental, social, and governance (ESG) considerations publicly.

What is ESG article? ›

ESG stands for environmental, social and governance. These are called pillars in ESG frameworks and represent the 3 main topic areas that companies are expected to report in. The goal of ESG is to capture all the non-financial risks and opportunities inherent to a company's day to day activities.

What is SFDR and EU taxonomy? ›

The EU Taxonomy is the fundamental cornerstone of a suite of regulation to be launched by the EU to improve and standardise sustainability reporting. In particular, the Taxonomy will support the Sustainable Finance Disclosure Regulation (SFDR) and the upcoming Corporate Sustainability Reporting Directive (CSRD).

How do you measure SFDR? ›

The meaning of SFDR

General use of DB, expressed as: SFDR=Ps-Pn, SFDR is the spurious-free dynamic range ( dB ), Ps is a useful signal power ( dBm ), Pn is the largest clutter signal power value ( dBm ).

What are the three dimensions of ESG? ›

Basically, sustainability in a business context encompasses these three dimensions: Environmental, Social and Governance. In other words, it is the framework for responsible, corporate action that reconciles social and environmental concerns in business operations.

Who falls under Sfdr? ›

The SFDR applies in full if your business meets the following categories: Financial market participant or financial advisor. Based in the EU. 500+ employees.

What is double materiality? ›

As it relates to ESG, and specifically to climate change and its effects, double materiality examines the potential impact of climate change on the financial health and outlook of a company. As an illustration, consider warming temperatures and rising sea levels and what these mean for the oil and gas industry.

What does ESG stand for? ›

What is environmental, social and governance (ESG)? Environmental, social and governance (ESG) is a term used to represent an organization's corporate financial interests that focus mainly on sustainable and ethical impacts. Capital markets use ESG to evaluate organizations and determine future financial performance.

What is EU Sfdr regulation? ›

The Sustainable Finance Disclosure Regulation (SFDR) is a European regulation introduced to improve transparency in the market for sustainable investment products, to prevent greenwashing and to increase transparency around sustainability claims made by financial market participants.

What are the 3 principle of sustainability? ›

The principles of sustainability are the foundations of what this concept represents. Therefore, sustainability is made up of three pillars: the economy, society, and the environment. These principles are also informally used as profit, people and planet.

Why is Tesla not ESG? ›

In its 2021 Impact Report, Tesla said that “current ESG evaluation methodologies” are “fundamentally flawed” because it lacks focus on the company's “real-world impact” on society and the environment.

What is the difference between ESG and sustainability? ›

ESG is based on standards set by lawmakers, investors, and ESG reporting organizations (e.g., GRI, TCFD, MSCI), whereas sustainability standards — while also set by standards groups like GHG Protocol — are more science-based and standardized.

What is the difference between SFDR and NFRD? ›

Hence, for investors NFRD is mostly relevant because it stipulates how investee companies report ESG data. SFDR, by contrast, most concerns financial market actors and ensures transparency about how these report on sustainability risks to their audiences (e.g., retail investors).

Is the EU taxonomy mandatory? ›

European Commission adopts CSRD proposal

Taxonomy reporting would be mandatory for all companies within the scope of CSRD.

What are the objectives of the EU taxonomy? ›

The six environmental objectives of the Taxonomy are: (1) climate change mitigation, (2) climate change adaptation, (3) sustainable use and protection of water and marine resources, (4) transition to a circular economy, (5) pollution prevention and control, and (6) protection and restoration of biodiversity and ...

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