SFDR RTS and EU-Taxonomy – Increasing transparency on the sustainability of investments – June 2022-June 2024

Largest Belgian Asset Manager with EU branches and cross-border distribution

Taking over the SFDR epic owner role on the project in order to deliver the project in a timely and qualitative manner.

Supporting the EU’s Green Deal

The Sustainable Finance Disclosure Regulation (SFDR) is a pivotal component of the EU’s Green Deal, aimed at transitioning capital flows towards sustainable investments to achieve carbon neutrality by 2025, as set by the 2016 Paris Agreement.

SFDR Requirements

The SFDR requires financial market participants (FMPs) and financial advisers to disclose at both entity and product levels how they integrate sustainability risks and principal adverse impacts into their investment decision-making processes. It also introduces additional product disclosures for financial products making sustainability claims.

Increasing transparency and investor protection

The objective of the regulation is to provide transparency to investors, to strengthen investor protection and to make it easier for investors to compare financial products and services on their sustainability claims and consequently, to guide their investment decisions.

Regulatory technical standards (RTS)

The SDFR RTS specify the methodology, content and presentation of information to be disclosed at product level (precontractual documents, sustainability-related websites disclosures and periodic reports) and at entity level (principle adverse impact indicators (PAI) statement and website disclosures). 


All Article 8 (promotion) and 9 (objectives) products (funds, T21, T23, mandates) were impacted and all group, banking and insurance entities were involved, along with other distributors. The entity level PAI statement involves all investment decisions, including conventional Article 6 products.

Moving target

The SFDR RTS had to be implemented considering incremental guidance from three European supervisory authorities (European Banking Authority (EBA), the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA)) and sometimes deviating FAQs and review comments from several national supervisors. Consequently preparations had to be adapted in an agile way, while meeting the strict regulatory deadlines.

Soon after the introduction on 1 January 2023, an update to the SFDR RTS was released on 17 February 2023.

To keep the in-house Responsible Investing methodology competitive and compliant, a yearly review cycle was initiated, introducing changes to the disclosures.

EU-Taxonomy in SFDR and NFRD

Given the relationship between SFDR and the EU-Taxonomy classification system of environmentally sustainable investments, the asset management-related part of the corporate Non-Financial Reporting Directive (NFRD) reporting was also in scope of the project (reporting over 2023 in the group annual report). Also the first preparations for the implementation of the Corporate Sustainability Reporting Directive (CSRD) based on the European Sustainability Reporting Standards (ESRS) by the European Financial Reporting Advisory Group (EFRAG) were supported.

Other related topics

Other related activities were added to the scope along the way, including EC Consultations for SFDR review and the SFDR precontractual and periodic data collection exercises by the Commission de Surveillance du Secteur Financier (CSSF).

Future updates in the pipeline

The SFDR RTS is a dynamic framework, subject to further updates. An impact assessment of the pending SFDR RTS update was made, while an ongoing broader SFDR review might introduce further changes.


Pending further internal and external updates, the opportunity was taken to implement further organisational and operational (e.g. automation) improvements and to hand over the epic to an internal epic owner.

Ready to assist

Phibonacci will continue to closely monitor developments in sustainability-related regulations and is ready to assist existing and new clients in further implementation.


  • Complex Regulatory Requirements: Navigating the detailed and evolving requirements of SFDR RTS and its updates.
  • Agile Adaptation: Adapting methodologies, systems, and processes in response to RTS updates, incremental guidance and comments from multiple supervisory authorities.
  • Interpretation and Compliance: Ensuring compliance with detailed disclosure standards, which can be open to interpretation, while maintaining consistency across different products and entities.
  • Regulatory Deadlines: Meeting strict regulatory deadlines.
  • Coordination Across Multiple Entities: Ensuring collaboration among various departments, group entities and external distributors.
  • Stakeholder Communication: Keeping all stakeholders informed and aligned.
  • Data Collection, Calculations and Reporting: Gathering accurate data, set-up and testing of calculations and data flows for reporting purposes.
  • Parallel Projects and Initiatives: Simultaneously addressing other regulatory changes (e.g. PRIIPS RTS, ESG in MiFID/IDD) that impact investor interactions.
  • New Product Launches: Ensuring disclosures for newly developed responsible investing products, which often introduced new strategies and required changes to methodology and systems to prepare the SFDR disclosures.
  • Resource Constraints: With limited availability of typical project roles and scarce resources, ensuring a qualitative delivery was challenging.
  • NFRD Challenges: Coping with data availability, data quality and system performance issues.


  • Epic Owner Role: Take ownership of the project, define clear milestones, allocate resources, and establish communication channels.
  • Incremental Implementation: Break down the implementation into manageable phases, prioritize critical aspects (e.g. ensure system changes are included in the SAFe PI planning via Lean Business Cases) and gradually roll out changes.
  • Collaboration with Authorities: Seek guidance and engage with supervisory authorities to ensure alignment with their expectations.
  • Cross-Functional Teams: Form cross-functional teams involving legal, compliance, IT, reporting operations, and business units and regularly coordinate.
  • Agile Adaptation: Use agile methodologies to update methodology, core system, data warehouse and reporting systems, to respond to evolving regulatory and market requirements with iterative updates and adjustments.
  • Proactive Stakeholder Engagement: Engage with distributors to share SFDR ESG data for informed product alignment, maintain regular communication with internal and external stakeholders, and organize training sessions and workshops.
  • Leverage Existing Governance: Utilize existing governance frameworks and leverage the group-wide MiPS Programme (MiFID, PRIIPS, and SFDR) for cross-border alignment and consistency.
  • Compliance and Quality Assurance: Implement rigorous compliance checks and quality assurance processes to identify and rectify discrepancies.
  • Technology and Tools: Utilize advanced technology solutions for data management, reporting and compliance tracking and use tools to support agile project management and real-time collaboration.
  • Documentation and Reporting: Maintain up-to-date documentation of processes, methodologies and incremental changes.


  • Regulatory Adaptability: Successfully navigated complex regulatory landscapes, reflecting dedication to meeting evolving regulatory and market demands, while upholding the highest possible quality standards.
  • Enhanced Compliance: Contributing to the overarching objectives of the EU’s Green Deal and reducing the risk of regulatory penalties by full compliance with SFDR RTS and its updates.
  • Enhanced Transparency and Accountability: Improved transparency for investors regarding sustainability risks and impacts, fostering trust and informed decision-making.
  • Strengthened Investor Protection: Strengthened investor protection through accurate and consistent sustainability disclosures.
  • Sustainability Leadership and Competitive Advantage: Positioned the organization as a leader in responsible investing, enhancing its market reputation.
  • Organizational Readiness: Streamlined processes and organizational upgrades to ensure timely and accurate disclosures.
  • Agility and Adaptability: Built an agile and adaptable framework capable of responding to future market and regulatory changes.

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Largest Belgian Asset Manager with EU branches and cross-border distribution

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