Aug 15, 2024
Regulations
SFDR requires every EU fund to classify under Article 6, 8, 8+ or 9. Article 8 is the most common classification, but also the most misunderstood. Many fund managers assume exclusions and a few ESG statements are enough. Regulators and LPs, however, expect far more. In this guide, we’ll look at the top mistakes funds make when classifying as Article 8 and how to avoid them.
By
Rhea Colaso

Mistake 1: treating negative screening as sufficient
The problem: Many managers believe excluding sectors like tobacco or coal qualifies as Article 8.
The reality: Article 8 requires funds to promote ESG characteristics, not just avoid harmful industries.
Learn more: We explain this in detail in Is Negative Screening Enough for an Article 8 Fund?
Mistake 2: using generic or vague ESG language
The problem: Vague phrases like “we care about sustainability” don’t satisfy regulators.
The reality: SFDR requires specifics, which characteristics are promoted, how they’re measured, and how binding they are.
Learn more: See our SFDR Article 8 Fund Guide for a breakdown of disclosure templates and how to make them concrete.
Mistake 3: forgetting Principal Adverse Impacts (PAIs)
The problem: Many Article 8 funds ignore PAIs or assume they’re optional.
The reality: Even if you don’t consider PAIs, you must explain why in both your pre-disclosure and website disclosure. If you opt-in, the PAI disclosure must be completed annually.
Learn more: Our article on Annual Disclosure Requirements for SFDR Article 8+ and 9 Funds explains what needs to be included.
Mistake 4: misclassifying as Article 9 to sound “greener”
The problem: Some managers label themselves as Article 9 to attract LPs.
The reality: Article 9 requires a sustainable investment objective, mandatory PAIs, and often EU Taxonomy alignment. Misclassification risks greenwashing accusations.
Learn more: Check our comparison piece: What’s the Difference Between Article 8 and Article 9 Funds?
Mistake 5: ignoring website and periodic disclosure consistency
The problem: Funds update periodic reports but forget to update websites or LP reports, leading to inconsistencies.
The reality: Regulators and LPs cross-check and any mismatch undermines trust.
Learn more: Our Annual Disclosure Requirements guide shows how to align templates, websites, and reports.
Mistake 6: underestimating portfolio company readiness
The problem: Many funds assume startups can easily report ESG data. In reality, most lack systems.
The reality: Without templates or support, managers end up with gaps in their annual disclosures.
Learn more: Our piece How to Build ESG Into Your Investment Process Beyond Negative Screening explains how to introduce ESG realistically across the investment lifecycle.
Mistake 7: not linking ESG to value creation
The problem: ESG is presented as a compliance cost rather than a driver of growth.
The reality: LPs want to see ESG as a lever for resilience, efficiency, and fundraising advantage.
Learn more: See our article on [ESG as a Business Advantage] for examples of how ESG directly supports valuation.
This is not just about avoiding mistakes.
It’s about building trust. The funds that succeed are those that:
Go beyond exclusions.
Use clear, binding ESG criteria.
Support their portfolio companies in reporting.
Show LPs how ESG creates value.
With Planicorn, this process becomes easier. From data collection to template reporting, Article 8 compliance can be completed in under 30 minutes. Contact us to learn more.
