15 July 2020

New ESG transparency requirements – what impact for Luxembourg AIFMs and Management Companies?

Sustainability in general and sustainable financing in particular has gained more and more traction over the last years. Recently, however, a considerable number of legislative initiatives at a European level have turned it from a market trend into a new set of regulatory obligations that need to be complied with in the very near future. Following the 2016 Paris agreement on climate change and the United Nation’s 2030 Agenda for sustainable development goals, the European Commission devised its own action plan for financing sustainable growth in 2018.

Over the past months, these declarations of intent evolved into a number of concrete legal texts concerning the investment funds industry: The sustainable finance disclosure regulation (EU) 2019/2088 (“SFDR”) from November 2019 was the first and can be considered as having the most profound impact. It was complemented in April 2020 by draft regulatory technical standards concerning the disclosure obligations set out in the SFDR. Even more recently, drafts of a regulation amending the AIFM Regulation (EU) 231/2013 and of a directive amending the UCITS Directive 2010/43/EU were published in June 2020 to implement the principles laid out in the SFDR. In addition, the taxonomy regulation (EU) 2020/852 amending the SFDR and providing rules on the classification of environmental, social and governance investment (“ESG”) was issued on 18 June 2020.

The article is available for download as a PDF file; the whole edition is free to access on the AGEFI website.


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