SFDR data collection exercise on periodic disclosures

On 30 June 2023, the CSSF provides financial market participants with information regarding the launch of the data collection exercise relating to the disclosures in periodic reports for financial products disclosing under Article 8 or Article 9 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR).

What has the CSSF just published ?

This Communiqué follows up on (i) the CSSF communiqué published on 27 July 2022 announcing the intention of the CSSF to launch a data collection exercise related to SFDR and Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (Taxonomy) and (ii) the CSSF communiqué published on 24 March 2023 in relation to the data collection exercise dedicated to pre-contractual disclosures.

This data collection will focus on the information relating to the disclosures in periodic reports for financial products disclosing under Article 8 or Article 9 of SFDR.

The objective is to collect such information in a digital format on an annual basis.

What is the scope of such data collection ?

The CSSF notably requires Luxembourg-based (i) UCITS management companies in relation to all Luxembourg-domiciled UCITS they manage, (ii) authorised AIFMs, in relation to all Luxembourg-domiciled regulated and unregulated AIFs (including ELTIFs) they manage and (iii) internally managed alternative investment funds within the meaning of point (b) of Article 4(1) of the Law of 12 July 2013, to provide a set of information relating to disclosures in periodic reports, included in the annual reports issued as from 1 January 2023 and with a financial year-end on or after 30 September 2022, according to the following deadlines:

• For periodic reports issued, in accordance with the legal deadline to publish the annual report or to make it available to investors, between 1 January 2023 and 31 December 2023, information shall be provided to the CSSF by 31 January 2024 at the latest.
• For periodic reports issued as from 1 January 2024, information shall be provided to the CSSF, at the latest, one month after the legal deadline to publish the annual report or to make it available to investors.

The CSSF also specifies that this data collection is mandatory for all the (sub-) funds of a UCITS or AIF disclosing under Article 8 or 9 SFDR.

What’s next ?

In the near future, this data collection will be extended to principal adverse impacts (PAI) statements.