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Fund Regulation, Decoded

Regulatory updates, SFDR, AIFMD, CSDDD, and beyond, turned into clear next steps for your fund.

Run deal sourcing, due diligence, ESG reporting, LP compliance and everything in between, from your first portfolio company to your fiftieth.

Does the SFDR apply to registered (or sub-threshold) AIFMs referred to in the AIFMD?

How should small firms count employees for the SFDR Article 17 exemption?

Does a registered AIFM need a website to publish Article 8/9 SFDR disclosures?

Does SFDR apply to non-EU AIFMs marketing funds into the EU?

Can SFDR Article 6(1) be used to avoid other EU sustainability-risk obligations?

Can general-purpose equity or corporate debt count as a sustainable investment under SFDR?

What qualifies an economic activity as contributing to environmental or social objectives under SFDR?

What counts as “all investments” for PAI and Taxonomy calculations under SFDR?

How should short positions be treated in PAI indicator calculations?

Who counts toward the 500-employee threshold in SFDR?

Whose impacts must be disclosed in the due-diligence statement?

Can small FMPs ignore PAI at entity level but consider PAI for specific products?

What does “considering PAI” mean under SFDR Article 7?

Who counts toward the 500-employee PAI threshold under SFDR?

Do we need to disclose how much of our PAI data is estimated vs. reported?

How should “investee countries subject to social violations” be interpreted?

Why is "Investee countries subject to social violations" difficult for industry to calculate?

What guidance did the ESAs provide to help interpret social violations?

How should “incidents that lead to sanctions” be measured for Indicator 7.2?

Do financial sanctions like fines and penalties count as “sanctions” for SFDR?

Should we include sanctions against the FMP itself, or only sanctions against investee companies?

Do IORPs who voluntarily consider PAIs need to report against the mandatory PAI indicators?

How should PAIs be reported when part of a fund is delegated to another manager?

How should FMPs adjust PAI reporting when new CSRD data creates differences from earlier estimates?

How should I handle timing differences between current investments and enterprise value in PAI calculations?

For PAI "workdays lost" should I report absolute numbers or a weighted average?

How should banks interpret “enterprise value including cash (EVIC)” for SFDR PAIs?

What should I do if an investee company’s enterprise value is negative for SFDR indicators?

How do I complete the sovereign and real estate PAI indicators if I have no such investments?

How do I report the board gender diversity PAI if there are no male board members?

How do I calculate PAI "emissions to water" if no formula is provided?

How do I calculate fossil-fuel exposure for real estate in a multi-asset product?

Should GHG emissions for Indicator 18 be adjusted for the fund’s ownership share?

Should PAI "water usage and recycling" use a normal average or a weighted average?

How do I calculate GHG emissions if I hold a company for only half of the year?

Do sustainability-risk policies need to cover all investment decisions or only SFDR-relevant products?

Do Article 4 PAI disclosures apply only to SFDR products or to all portfolio-management investments?

Is PAI Indicator 4 a pass/fail check, or do we need to measure the share of fossil-fuel activity?

Do we disclose PAI 6 for all high-impact sectors combined, or separately for each sector?

Which exchange rate should be used when converting foreign-currency values to EUR for SFDR?

How should GHG emissions be reported when investments are held through UCITS or delegated products?

What does “water usage” mean under PAI Indicator 6?

What does “per square meter” mean for real estate PAI indicators?

What must be included when reporting actions taken or planned to reduce PAIs?

Do Article 9 products have to invest only in sustainable investments?

Can a product name using terms like “sustainable” or “ESG” automatically qualify it as an Article 8 product?

Is integrating sustainability factors or risks (without promoting ESG characteristics) enough to qualify as Article 8?

Does an Article 8 product need a minimum percentage of sustainable investments?

If a product has an ESG-related feature (like exclusions) but doesn’t advertise it, does it still count as “promoted”?

If a product follows a legal rule (like banning cluster munitions), does that automatically make it Article 8?

Do SFDR disclosures apply to custom client portfolios? And how do you handle client confidentiality when disclosures must be public?

Why is the EU reviewing the SFDR framework in 2025?

Is the new SFDR 2.0 framework official, and when will it apply?

What is included in the EU’s proposed new SFDR disclosure regulation?