Fund Distribution Alert 2020-09

Fund Distribution Alert 2020-09



Said Fihri

Partner, ADV – Investment Services

KPMG in Luxembourg


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ESAs open consultation on ESG disclosure rules

On 23 April, the three European Supervisory Authorities (ESAs) - the EBA, EIOPA and ESMA - issued a joint consultation paper on proposed environmental, social and governance (ESG) disclosure rules, called Regulatory Technical Standards (RTS).

The RTS are prompted by several obligations under the Regulation (EU) 2019/2088 (the “Sustainable Finance Disclosure Regulation” or “SFDR”) and aim to strengthen investor protection as well as improve disclosures on sustainability-related matters.

The draft RTS include:

  • Principal adverse impact disclosures, including:
    • a mandatory reporting template;
    • indicators – both mandatory and additional;
    • necessary statements if not considered; and;
    • financial adviser requirements.
  • Product disclosures rules at the following levels:
    • pre-contractual;
    • online;
    • periodic.

Fund houses have until 1 September 2020 to submit their feedback on the disclosure rules.

The consultation paper and the proposed rules are available here.

Please feel free to contact us should you require any additional information.


Said Fihri
+352 22 51 51 7892

Stephanie Zedda
Senior Manager
+352 22 51 51 7271

Please note that any information provided is general in nature, is based on the latest publicly available information as analyzed on a best endeavor basis and does not constitute any specific legal opinion or advice.

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