In brief
On 26 July 2021, the European Commission published a set of long-awaited Q&A guidance on the EU Sustainable Finance Disclosure Regulation (SFDR).
On 26 July 2021, the European Commission published a set of long-awaited Q&A guidance on the EU Sustainable Finance Disclosure Regulation (SFDR). The guidance was published in response to a request for a clarity by the European Supervisory Authorities on a number of specific points, many of which reflected issues raised by market participants that were left struggling to apply the Level 1 text of the Regulation from March this year.
The Commission’s guidance will be relevant in particular to:
- asset managers established outside of the EEA (e.g., in the UK, US or Switzerland) that market fund units into an EEA Member State under that jurisdiction’s national private placement regime; and
- any firm attempting to navigate Article 8 vs. Article 9 product characterisations, or that provides single managed account services within scope of the SFDR.
We have summarised in this alert some of the major points raised by the Commission’s guidance.
Click here to access full alert.
Author
Caitlin McErlane
Caitlin McErlane is a partner in Baker McKenzie’s Financial Services & Regulatory Group in the London office.
Caitlin's practice focuses on advising a range of global financial institutions on complex and high value regulatory matters. She advises banks, major corporates, payment institutions and asset managers on navigating UK and EU financial services regulation. She has particular experience in advising clients on regulatory implementation projects, day-to-day compliance issues, and regulatory issues arising in the context of large-scale transactions. She also expertise in the areas of banking and wholesale financial markets regulation, in particular in the FX and fixed income space, alongside experience advising market infrastructure providers, including major international exchanges, trading platforms, clearing systems and payment services providers, on a variety of compliance issues.
Caitlin is also a member of the Baker's ESG and sustainability taskforce, and advises a range of clients on the drafting and implementation of ESG policies and the implications of becoming a signatory to the UNPRI and the Stewardship Code. Caitlin is an authority on regulatory reforms in the sustainability space and sits on a number of trade association working groups. She has recently been interviewed by Climate Action on her work and is a frequent speaker on the subject.
