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 yet another follow-up to previous announcements made by the CSSF on 27 July 2022, 24 March 2023 and 30 June 2023 (see eventid=16863, eventid=20211 and eventid=22061), indicating its intent to conduct a data collection exercise related to the SFDR and TR.
More specifically, the present communiqué serves as an update to the previous CSSF communiqué issued on 30 June 2023, which announced the initiation of a data collection exercise relating to the disclosures in periodic reports for financial products that fall under either Article 8 or Article 9 of the SFDR.
The purpose of this new communiqué is to notify industry participants that the scheduled online solution, accessible through eDesk, has been made available since 30 November 2023 for manual input by IFMs and IORPs for each fund or sub-fund they manage. This online solution complements the existing option of submitting the data via a structured file using the S3 protocol.
To assist industry participants in navigating this process, the user guide has also been revised on 30 Novmber 2023 and can be accessed under the title 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 update to the user guide published on 30 November 2023 removed paragraphs regarding the transmission of reports via S3. The method of transmitting reports via S3 is now referenced by a document available on the website. The specific Q&As section has been removed. The online eDesk form for submitting reports (see point 4.2) is covered, and an “SFPER018” feedback message has been added for submission via S3. As before, the guidance includes 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