ESAs’ Q&A on Sustainability-Related Disclosures

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On 17 November 2022, the ESAs (ESMA, EIOPA, and EBA) published Questions and Answers (“Q&A”) on the SFDR Delegated Regulation (Commission Delegated Regulation (EU) 2022/1288 (“RTS”)).

The Q&A has been published in response to clarifications sought by financial market participants (“FMPs”) on the disclosure requirements imposed under the RTS.


The Q&A covers six key topics:

  1. Current value of all investments in PAI and Taxonomy-aligned disclosures
  2. PAI disclosures
  3. Financial product disclosures
  4. Multi-option products
  5. Taxonomy-aligned investment disclosures
  6. Financial advisers and execution-only FMPs

Key points

Some of the most notable elements of the Q&A include the following:

According to the Q&A, the basis used to calculate the “current value of all investments” in the PAI indicators should be consistent with the definition of the “investee company’s enterprise value”.

With respect to the concept of “all investments”, the Q&A specifies that:

-  For PAI calculations, “all investments” should be understood to mean both direct and indirect investments funding investee companies or sovereigns.

Additional considerations are set out for the PAI calculations of asset managers, insurers, IORPs and banks or investment firms providing portfolio management or investment advice services.

-  For Taxonomy-alignment calculation, the investments in the numerator and denominator should be valued at market value and not at “net asset value”.

FMPs may remove the sections that are deemed not relevant for their financial product in the disclosure templates only if those sections are accompanied by a red text instruction limiting the scope of application of the section.

  The objective-aligned index designated as a reference benchmark may not be a broad market index.

  With respect to MOPs:


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To read the Q&A, click here_

To read our newsflash on the new CSSF FAQ – Sustainable Finance Disclosure Regulation, click here_

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Luxembourg Newsflash – ESAs’ Q&A on Sustainability-Related Disclosures

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