Representatives of the Irish Funds ESG Policy, Legal and Regulatory Working Group, including Head of Matheson's Asset Management and Investment Funds Department, Tara Doyle, recently met with the Central Bank of Ireland ("Central Bank") to discuss the Irish Funds submission to the Central Bank requesting a fast-track for the implementation of the Level 2 requirements under the Sustainable Finance Disclosure Regulation ("SFDR").
At the meeting, the Central Bank confirmed its intention to apply a stream-lined review process or "fast-track" to SFDR Level 2 filings. The deadline for filings using this process will be 1 December 2022. The Central Bank also confirmed that it intends to apply similar conditions to the Level 2 fast-track as applied to the previous fast-tracks for SFDR Level 1 and Taxonomy Level 1. There will be a sample review of filings after the filing deadline has passed. Broader SFDR-related changes, other than those required under the Level 2 regulatory technical standards, will be allowed within the fast-track process. Filings must be accompanied by an attestation from a responsible person, certifying that the changes being made relate to SFDR only. The cover letter accompanying the filing should also identify and provide an explanation of any of the changes that are being made to align with the SFDR and recent EU level regulatory clarifications.
The Central Bank will publish a document setting out the final conditions applicable to the fast-track, which will take into account the various requests made by industry representatives at the meeting. We will update our clients and contacts as soon as this document is available.
Please contact your usual Asset Management and Investment Funds Department contact should you have any questions in relation to the fast track process.