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Redefining SFDR: new product categorisation proposed by the Platform on Sustainable Finance

14 March 2025

Cristian Echavarría and Jose Luis Marchante

The European sustainable finance landscape continues to develop, and the recent proposal by the EU Platform on Sustainable Finance marks a significant step forward. With a focus on enhancing the Sustainable Finance Disclosure Regulation (“SFDR”), the proposal aims to introduce a structured categorisation framework that brings clarity to financial products and aligns with investor expectations.

Background    

This proposal stems from a broad mandate issued by the European Commission to the European Platform on Sustainable Finance (“EUPSF”) - a consultative body- through a public consultation process launched in September 2023. In response, the EUPSF provided feedback on the SFDR Level 1 advocating for a fundamental reform of the framework.

Earlier, in July 2023, the EUPSF had already signalled the need for change in its “SFDR RTS Brief”, reinforcing the call for a more effective and transparent regulatory structure.

Regulatory concerns around SFDR have also been raised by European regulatory bodies. In June 2024, the European Supervisory Authorities (“ESAs”) issued a statement echoing the need for significant revisions to the regulatio

Why is a new categorisation proposed?

In accordance with the EUPSF, the SFDR has been instrumental in improving transparency around sustainability-related financial products. However, its implementation has led to inconsistencies in market interpretations, varied national labelling regimes, and a lack of clarity for investors.

The proposed categorisation framework seeks to address these challenges by providing a clear and structured approach to classifying financial products based on their sustainability objectives. It introduces three primary categories to better structure different sustainable investment strategies: 

SustainableTransitionESG collection

       
Definition Sustainable contributions through Taxonomy-aligned Investments or Sustainable Investments with no significant harmful activities, or assets based on a more concise definition consistent with the EU Taxonomy. Supports the transition to net zero and a sustainable economy, avoiding carbon lock-ins, in line with the European Commission's recommendations on facilitating finance for the transition to a sustainable economy. Excludes significantly harmful investments/activities, investing in assets with better environmental and/or social criteria or applying various sustainability features.
Minimum criteria
  • A minimum percentage of the investments contribute through Taxonomy-aligned or environmental and/or social Sustainable Investments.
  • All investments outside of those mentioned above must pass the Do No Significant Harm (“DNSH”) test through the Principal Adverse Impacts (“PAIs”), except for hedging and liquidity instruments. In addition, PAIs for the DNSH test must be prioritised based on relevant sustainability characteristics.
  • EU Paris-Aligned Benchmarks (“PABs”) exclusions.
  • A minimum percentage of investments are transitioning with measured transition pathways/plans on portfolio and/or product level by identifying established relevant criteria.
  • Any other assets must not undermine the transition objective.
  • EU Climate Transition Benchmarks (“CTBs”) exclusions. 
  • A minimum percentage of investments follow one or a combination of one or more material sustainability feature.
  • Materiality to be defined through established criteria with a focus on environmental, social and/or Governance.
  • Any other assets must not undermine the ESG characteristics/features
  • EU Climate Transition Benchmarks (“CTBs”) exclusions.
Indicators to measure
  • Share of the Taxonomy alignment and sustainable investments.
  • PAIs.
  • Adherence to determined exclusions.
  • Indicators linked to the additional binding elements, if defined by the FMP.
  • Indicators to measure credible transition pathways or plans on portfolio and/or investment level. These depend on binding elements, but some are established.
  • Indicators linked to the additional binding elements, if defined by the FMP.
  • Indicators to measure the determined Materiality, i.e., depending on binding elements. Some are already established.

Investment strategies that do not fall within the newly proposed categories will be classified as unclassified products.

The proposed reform marks a significant shift from the current SFDR framework, posing challenges for financial market participants (“FMPs”) in managing the transition. To ease this process, the EUPSF advocates for an interim solution, including the temporary recognition of current Article 9 strategies as a standalone category.

The road ahead

There is currently no definitive timeline for implementing the new proposal, though some indicative dates have been suggested. Notably, the European Commission recently published its annual work programme, outlining that the review of the SFDR will take place in Q4 2025. If this timeline holds, the legislative process could commence in 2026, with the regulation potentially coming into force by 2028. However, these dates remain subject to change.

A significant overhaul of the SFDR framework is on the horizon, making it essential for FMPs to rethink and adapt their strategies. At Holtara, we are ready to help you stay ahead of these changes, offering the expertise and strategic support needed to navigate SFDR compliance with confidence.