Launch of the SFDR data collection for investment fund managers

On 1st February 2023, the Commission de Surveillance du Secteur Financier (the CSSF) has published a communiqué to provide the industry participants with information on the launch of the first part of the data collection related to SFDR as mentioned in the CSSF communiqué of 27 July 2022.

What has the CSSF just published?

The first part of this data collection will focus on the collection of information on organisational arrangements of investment fund managers (IFMs) related to Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR).

The CSSF expects the organisational arrangements of the IFMs to take account of the integration of sustainability risks, notably in terms of human resources and governance, the investment decision or advice process, the remuneration and risk management policies and the management of conflicts of interest.

SFDR indeed requires IFMs that qualify as financial market participants and/or financial advisers to comply with rules in respect of the integration of sustainability risks since 10 March 2021.
Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing SFDR (SFDR RTS), applicable as of 1st January 2023, provides further details on the transparency to be ensured by these IFMs.

What is the scope of such data collection?

The CSSF requires notably Luxembourg-based (i) UCITS management companies and (ii) authorised AIFMs, including internally managed alternative investment funds within the meaning of point (b) of Article 4(1) of the Law of 12 July 2013, to complete a questionnaire via the launch of a new eDesk module named “SFDR-IFM disclosures” from 2nd February 2023.

The questionnaire must be submitted at the latest on 2nd March 2023 through eDesk. In order to submit the questionnaire, the eDesk user has to be linked to the IFM.

IFMs have to make sure that the answers set out in the questionnaire are kept up to date.

What’s next?

In the near future, this data collection will be extended to precontractual and periodic disclosure templates and to principal adverse impacts (PAI) statements.