How should small firms count employees for the SFDR Article 17 exemption?
SFDR Article 17; Regulation (EU) 2019/2088
In simple words
All workers count toward the “fewer than three persons” threshold, including part-time staff, contractors, owners, and self-employed workers. Employment status doesn’t matter.
Official question
Article 17 of Regulation (EU) 2019/2088 exempts insurance intermediaries which provide insurance advice with regard to IBIPs and investment firms which provide investment advice that are enterprises irrespective of their legal form, including natural persons and self-employed persons, provided that they employ fewer than three persons. As there is no definition of “employ” or “employee” in Regulation (EU) 2019/208, how are self-employed staff, owner managers or part-time employees counted?
Official answer
The headcount in Article 17 of Regulation (EU) 2019/2088 applies regardless of the features of the employment relationship, i.e. part or full-time.
Answered by
European Comission
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