Central Bank of Ireland published a clarification on the process for UCITS and AIFs Following ESMA’s New Guidelines on ESG Fund Names

In September 2024, the Central Bank of Ireland provided clarifications as to the process for UCITS and AIFs seeking compliance with ESMA’s guidelines on using ESG or sustainability-related terms in fund names. These guidelines, published on August 21, 2024, will apply from November 21, 2024, for new funds, and from May 21, 2025, for existing funds. The guidelines aim to regulate how UCITS management companies and AIFMs (alternative investment fund managers) name their funds to ensure accuracy in ESG-related information.

We have provided a helpful table on the application of the ESMA Guidelines here.

 Streamlined Filing Process

The Central Bank has introduced a streamlined process for UCITS and AIFs to update fund names and related documents (prospectuses, supplements, and SFDR annexes) in line with ESMA’s guidelines. In this regard, managers must submit an attestation confirming that changes are solely for compliance with the guidelines. The submission must include updated documents, sent to a dedicated email address.

Key Filing Steps

1. for Name Changes in compliance with the ESMA Guidelines: Use the streamlined process with an attestation of compliance.
2. for SFDR-Related Disclosures and Fund Reclassification: Use the Central Bank’s standard post-authorization process via the Portal.

Filings must be completed within the transition period (November 21, 2024, to May 21, 2025) for existing funds. New funds created after November 2024 must comply immediately. After May 2025, the streamlined process will no longer be available.

Do not hesitate to contact the ESG legal Zeidler Team for any assistance or questions in this regard.