• Deborah

On 18 November, ESMA released its Consultation Paper to gather feedback on the use of ESG or sustainability-related terms in fund names.


The Proposed Guidelines will apply to requirements under the UCITS Directive, AIFMD and Regulation 2019//1156 (cross-border distribution of investment funds).


Key provisions include:

  • General requirements pertaining to fund’s names in fund documents or marketing communications to tackle greenwashing.

  • Proportion of investments for funds’ names using ESG or sustainability-related terms, notably

  • A minimum proportion of at least 80% of the fund’s investments if a fund has any ESG-related words in its name.

  • Inclusion of an additional threshold of at least 50% of minimum proportion of sustainable investments for the use of the word “sustainable” or any other sustainability-related term in the name of the fund.

  • Funds that designate an index as a reference benchmark

  • Specific provisions for “impact” or impact-related names in these Guidelines


Comments must be submitted by February 20, 2023.

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