As we move further into 2025, sustainable finance continues to dominate the regulatory agenda. For fund managers distributing across Europe, staying on top of shifting disclosure expectations is critical not only to remain compliant, but also to maintain investor confidence in sustainability claims.
In August 2025, the European Supervisory Authorities (ESAs) released a set of new Q&As under the Sustainable Finance Disclosure Regulation (SFDR). These clarifications directly impact the way managers prepare periodic reports for Article 8 and Article 9 products. The latest guidance has been integrated into our Global Knowledge Hub (GKH) to ensure subscribers can access the most up-to-date, jurisdiction-specific insights.
The ESAs have clarified how managers should calculate and present “top investments” within periodic disclosures. The new Q&As provide additional direction on ensuring consistency across fund reporting, reducing the risk of interpretative divergence between market participants.
Guidance was also issued on defining and disclosing the minimum proportion of environmentally and socially sustainable investments. Managers must ensure that periodic reports align with the stated investment strategy and binding commitments, supporting greater comparability across Article 8 and 9 funds.
These updates apply immediately and will be of particular importance as firms prepare Q3 and Q4 reporting cycles.
Our Global Knowledge Hub (GKH) has been fully updated to reflect these SFDR clarifications. The platform provides expert-curated content on:
With coverage across 80+ jurisdictions and backed by our international legal team, the GKH equips managers with the tools they need to manage compliance efficiently — all at a fixed annual subscription fee, with the option to consult directly with our lawyers when additional support is needed.
