SFDR data collection exercise applicable to investment fund managers (IFMs) and institutions for occupational retirement provision (IORPs) on precontractual 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)

The CSSF has announced the launch of a data collection exercise in connection to precontractual product disclosure information relating to the SFDR and TR.
Indeed, IFMs and IORPs qualifying as FMPs are required to include sustainability-related information in the precontractual disclosures of financial products in accordance with SFDR, TR and the SFDR RTS.
The CSSF is requiring UCITS management companies, authorised AIFMs, registered AIFMs, and IORPs to participate in this data collection exercise by providing a set of information relating to precontractual product disclosures for each of the financial products they manage.
A corresponding SFDR UCI Data collection – Practical and technical guidance, which includes an FAQ and a Synopsis on information to be collected for sub-funds [not] disclosing under SFDR Article 8 or SFDR Article 9 has been made available by the CSSF, providing clarifications on the content and format of the information to be reported, as well as technical details on the data collection process.
The reporting of SFDR data is mandatory for all sub-funds of a UCITS/AIF/IORP subject to the scope as defined above. After the initial declaration, IFMs and IORPs remain responsible for ensuring that the information provided is up-to-date.
The deadline for submission of the initial report is 15 June 2023. The SFDR data can be submitted to the CSSF via a structured file through the automated S3 protocol, or an online solution via eDesk, which will be made available as of 2 May 2023.
The data collection exercise will be extended in the near future to collect information contained in the PAI statements and in the periodic disclosure templates.