On 18 December 2024, CSSF published updated FAQ on SFDR
The update consisted in removing questions 2 (SFDR templates as a material change), 9 (EPM techniques) and 10 (application date for periodic disclosures) as well as to update Q&A 6 and 7.
Q&A 6 was updated in order to specify that investment funds disclosing under article 9 may include, in addition to sustainable investments, other investments “used for hedging or relating to cash held as ancillary liquidity, which need to fit the overall sustainable investment objective of the fund” (the previous FAQ referred to “other investments for certain specific purposes such as hedging or liquidity”).
Q&A 7 was updated in order to integrate ESMA's guidelines on funds names using ESG or sustainability- related terms (the “Guidelines”) implemented by CSSF circular 24/863. The CSSF expects IFMs regardless of whether they disclose under article 6, 8 or 9 of the SFDR to carry out a self-assessment of the applicability of the above mentioned Guidelines to the products they manage but also to ensure compliance of these. The IFM is to ensure the ongoing compliance with all applicable thresholds and exclusions foreseen in the Guidelines, the depositary being in charge of the independent monitoring of such compliance according to its depositary oversight duties.
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