SFDR: Which groups have the most Article 8/9 funds? - ESG Clarity (2023)

Asset managers are being cautious in their approach to classifying their funds as Article 8 or 9 under new EU legislation Sustainable Finance Disclosures Regulation (SFDR), but already some €2.5trn in European fund assets is estimated to sit under these categories and the number is expected to grow over the coming months.

Level 1 SFDR, which came into force on 10 March, requires asset managersto publish both pre-contractual statements (e.g. in a fund’s prospectus) and disclosure statements on their websites about which of their products fall into three distinct categories. 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.
  • Article 6 funds: funds that are not promoted as having ESG factors or objectives.

Research from Morningstar in the report SFDR – The First 20 Days, which has collected SFDR data on close to 50% of funds (i.e. 5,695) domiciled in Luxembourg, Europe’s largest funds domicile, said preliminary data from 30 asset managers found funds classified as Article 8 and 9 currently represent up to 21% of total European funds and up to 25% of total European fund assets.

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This means the current European ESG and sustainable fund market, based on SFDR definitions, could therefore be worth as much as €2.5trn.

Below is the current lists of Article 8 and 9 funds on offer from asset managers surveyed:

SFDR: Which groups have the most Article 8/9 funds? - ESG Clarity (1)

The report noted: “Following the first classification exercise, we found that French managers Amundi and BNP Paribas offer some of the largest ranges of investment products classified as Article 8 or 9, with 529 and 310 funds, respectively. Other managers have chosen to classify far fewer funds as Article 8 or 9. It is the case even for firms of similar size or bigger, such as BlackRock, which has 103 classified products. UBS and JP Morgan have classified 54 and 10 of their funds as Article 8 or 9 products.”

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However, the report noted asset managers have taken different approaches in their interpretation of the rules and some have been more cautious for fear of having to downgrade funds later.

Therefore, Morningstar said it expects the numbers of funds being categorised as Article 8 and 9 will grow in the coming months as asset managers reclassify funds, enhance existing strategies and launch new ones that meet the requirements.

Hortense Bioy (pictured), global director of sustainability research at Morningstar and editorial panellist for ESG Clarity, commented: “It is clear from the asset managers we spoke to, of various nationalities and sizes, that it is essential for them to have as many funds as possible classified as Article 8 or 9 under SFDR. They see compliance with at least Article 8 requirements as an opportunity to demonstrate their commitment to sustainable investing. Morningstar will continue to watch this space closely and develop the tools that investors need to navigate through it.”

Scope of assets

Morningstar’s report noted that when the figures were looked at through the lens of absolute number of funds in Article 8 or 9 as a percentage of total assets, the picture looked quite different:

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SFDR: Which groups have the most Article 8/9 funds? - ESG Clarity (2)

Nordic and Dutch asset managers feature among those with the highest proportion of fund assets in Article 8 and 9.

“This is hardly surprising given the long history and commitment to responsible investing of institutional investors in Northern European countries,” the report said. “For example, Robeco has classified 96% of its fund assets as Article 8 or 9, while KLP and SEB have 95% and 82% of their fund assets, respectively, in the two categories. Sustainability-focused boutique Mirova has positioned its full range of funds (25) in the Article 9 category.”

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Meanwhile, Amundi and BNP Paribas, the two largest providers of Article 8 and 9 products in the sample, classified 60% and 80% of their existing fund ranges as such, respectively, while large asset managers, including BlackRock, UBS, and JP Morgan, exhibit much lower ratios at 17%, 11%, and 1.5%, respectively.

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“Many of the surveyed managers, however, made it clear that this was just the first classification exercise and that they plan to bring additional funds into the Article 8 and 9 categories in the coming months,” the report noted.

It highlighted Amundi is aiming to get 75% of its total fund assets categorised under Article 8 and 9 by the end of the year, and JP Morgan “has opted for a prudent approach where only our existing sustainable funds will be classified as Article 8 or Article 9”, the group said in a client presentation.

Others, including DWS, UBS, Schroders, and Aviva, have shared similar plans.


1. Sustainable Finance Disclosure Regulation (SFDR) - what actions should asset managers be taking now?
(London Stock Exchange Group (LSEG))
2. A-Team LIVE Webinar: Meeting the requirements for the EU’s ESG Disclosures Regulation
(A-Team Group)
3. Practical application of SFDR
4. SFDR webinar - Sustainable Finance Action webinar
(Robeco Asset Management)
5. Requirements for Article 9 funds, Session #3 of the NET IMPACT & EU SUSTAINABLE FINANCE PROGRAM
(The Upright Project)
6. Bringing you up to speed on SFDR and the EU Taxonomy
(responsAbility Investments AG)
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