The long-awaited updated supervisory statement on the application of the Sustainable Finance Disclosure Regulation (“SFDR”) was recently published by the European Supervisory Authorities (“ESAs”), followed by a meeting between Irish Funds industry representatives (including Head of our Asset Management and Investment Funds Department, Tara Doyle) and the Central Bank of Ireland (“Central Bank”) to discuss implementation issues.
One important clarification arising from the discussions with the Central Bank relates to the need to further update disclosures in light of the updated ESAs’ supervisory statement and the Central Bank’s spot checks of submissions received. The Central Bank has indicated an initial view that, for Article 8 and Article 9 SFDR funds, any updates to disclosures informed by the sample review (including any explicit quantification of Taxonomy alignment, where relevant) could be incorporated into the filings they would make to incorporate Level 2 measures by 1 January 2023, unless the disclosures were otherwise being updated in the meantime.
We have set out in our briefing note the updates to the supervisory statement and a summary of the discussions with the Central Bank at the 5 April meeting.