• Deborah

On November 17, by the European Securities and Markets Authority (“ESMA”), published the Questions and Answers ("Q&A") on the SFDR Delegated Regulation RTS (Commission Delegated Regulation (EU) 2022/1288) prepared by the three European Supervisory Authorities (EBA, EIOPA and ESMA).


The Q&A provide clarity on the following:

  1. Meaning of current value

  2. What the terms "all investments" should encompass. The elements to be taken into account for Principal Adverse Impact (PAI) calculations & Taxonomy-alignment calculation.

  3. Disclosure of short positions with regard to PAI disclosures.

  4. PAI disclosures: including but not limited to products that are partly taxonomy-aligned, products with 100% non-Taxonomy compliant climate objectives, issues related to lack of data, review by the third party…).

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