SFDR data collection exercise applicable to investment fund managers (IFMs) and institutions for occupational retirement provision (IORPs) on periodic disclosures in relation to Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (TR)

This CSSF Communication is a follow-up to previous announcements made by the CSSF on 27 July 2022 and 24 March 2023, indicating its intent to conduct a data collection exercise related to the SFDR and TR (please see eventID#16863 and eventID#20211). The objective of this Communication is to inform industry participants about the launch of the data collection exercise for financial products that disclose under Article 8 or Article 9 of SFDR.
SFDR establishes transparent rules for providing sustainability-related information regarding financial products, while TR introduces additional disclosure requirements for products making sustainable investments with environmental objectives. The Commission Delegated Regulation (EU) 2022/1288 (SFDR RTS) provides further details on transparency for FMPs.
IFMs and IORPs qualifying as FMPs are required to include sustainability-related information in the periodic reports of financial products disclosing under Article 8 or Article 9 of SFDR. The data collection exercise aims to gather this information in a digital format annually, according to the financial year-end of the products.
The CSSF mandates the participation of specific FMPs in the data collection exercise, including UCITS management companies, UCITS investment companies without designated management companies, authorized AIFMs, internally managed alternative investment funds, registered AIFMs, and IORPs subject to the AIFM Law. Participation in the exercise is also mandatory for all (sub-)funds of a UCITS/AIF/IORP disclosing under Article 8 or 9 of SFDR and falling within the defined scope. Some FMPs have the option to participate voluntarily in relation to any Luxembourg-domiciled regulated AIF they manage.
FMPs must provide the required information for each financial product within specific deadlines, depending on the issuance of periodic reports. The submission deadlines vary based on the financial year-end, with different timeframes for UCITS, AIFs, and IORPs.
To facilitate the process, FMPs can submit the SFDR data to the CSSF using two channels:
– a structured file through S3 protocol; or
– an online solution via eDesk, available from 30 November 2023.
The current data collection exercise will later be extended to include information from PAI statements, with further details communicated at a later stage. Any inquiries can be addressed to ucisfdr@cssf.lu.
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The CSSF also provides a SFDR UCI periodic data collection – Practical and technical guidance with clarifications and technical details for financial market participants on the SFDR Data collection exercise for products governed by Article 8 or Article 9. It covers data scope, completion expectations, reporting system overview, data format, and validation processes. The guidance also includes an FAQ and four annexes:
ANNEX I – Synopsis on Information to be Collected for Sub-Funds Disclosing under SFDR Article 8
ANNEX II – Synopsis on Information to be Collected for Sub-Funds Disclosing under SFDR Article 9.
ANNEX III – Synopsis on Information on Top Investments Information to be Collected for Sub-Funds Disclosing under SFDR Article 8 or SFDR Article 9.
ANNEX IV – Codes Required in the Report for Closed Questions