Disclosure Frameworks

Sustainable Finance Disclosure Regulation (SFDR)

What is the Sustainable Finance Disclosure Regulation (SFDR)?

The Sustainable Finance Disclosure Regulation - also known as SFDR - is an initiative by the European Union that encourages financial service providers and owners of financial products to disclose their environmental, social, and governance (ESG) policies publicly. 

It came into effect in March 2021, and its core aim is to promote sustainability in the finance sector by distributing capital towards sustainable investments and integrate sustainability into the EU's financial system. By enhancing transparency and providing clearer information, the SFDR seeks to enable investors to make more informed decisions and contribute to the transition towards a more sustainable economy.

As part of the European Commission's Action Plan on Sustainable Finance, the SFDR was introduced alongside the Taxonomy Regulation and the Low Carbon Benchmarks Regulation, forming a set of legislative measures.

How does SFDR categorize products?

The SFDR categorizes financial products into three categories, known as articles 6, 8, and 9. These enable investors to identify financial products that align with their sustainability preferences and provide greater transparency regarding the sustainability characteristics and objectives of the products offered in the market.

Article 6 - funds with no specific sustainability focus

Financial products falling under Article 6 are those that do not have explicit sustainability objectives. These products do not promote any particular environmental or social characteristics and do not consider sustainability risks in their investment decisions. 

They are essentially considered conventional financial products and are not subject to additional sustainability-related disclosures.

Article 8 - funds with environmental or social objectives

Financial products categorized under Article 8 have a specific sustainability focus and promote environmental or social characteristics. Article 8 funds are funds that promote and integrate ESG into their investment process. 

The disclosures for Article 8 products should explain how they contribute to environmental or social goals, allowing investors to identify investments that align with their sustainability preferences. Article 8 funds are referred to ‘light-green’ funds.

Article 9 - funds with a sustainable investment focus

Financial products falling under Article 9 have a strong and explicit sustainability focus. These products are considered sustainable investments, as they have sustainable investment as their primary objective. They must promote environmental or social characteristics and have a substantial impact in terms of contributing to sustainability goals. 

Article 9 products require more extensive and detailed sustainability-related disclosures to provide investors with comprehensive information about their sustainability features. Article 9 funds are referred to as ‘Dark-green’ funds.

Requirements under SFDR

If an organization is subject to the SFDR, they will need to fulfill specific disclosure obligations, which apply to both the entity level and the product/fund level. Depending on the organization or entity, the following will need to be disclosed on their websites:

Sustainability Risk Policy

This refers to the organization's approach to understanding and addressing environmental, social, and governance (ESG) risks that may impact its sustainability performance and long-term viability.

Principle Adverse Impact

In some cases, the entity will be required to disclose any investments that may negate sustainability efforts - sometimes known as PAIs. There are 64 separate PAI indicators that an investor may or may not have to disclose against. These indicators cover environmental and social considerations.

Sustainability Risk Remuneration Policy

This outlines how sustainability risks are incorporated into remuneration and compensation practices - such as incentive structures and rewards of employees and executives with the organization's sustainability goals and objectives.

How does SFDR relate to scopes 1, 2 and 3?

Regarding entity-level principal adverse impacts, the SFDR mandates companies to disclose information on 14 distinct sustainability factors, encompassing both climate-related indicators and social aspects. Among these factors, six specifically pertain to greenhouse gas (GHG) emissions.

Crucially, companies are required to report on the emission volumes of investee companies, which now include not only Scope 1 and Scope 2  emissions but, as of January 1st, 2023, Scope 3 emissions as well.

Is SFDR reporting mandatory?

Simply put, SFDR reporting applies to financial market participants (FMPs) and financial advisors operating within the EU, with more than 500 employees.  

Financial market participants with fewer than 500 employees are exempt from producing a principal adverse impact statement. Nevertheless, if they choose not to comply, they must provide a clear explanation for their non-compliance. The entities that apply to SFDR regulation include:

  • Asset managers
  • Institutional investors
  • Insurance companies
  • Pension funds

It’s important to note that the level and extent of reporting requirements may vary based on the entity's size and activities. 

Why it matters

Carbon disclosures, such as those under SFDR, have many benefits for organizations - whether reporting under such initiatives is mandatory for them or not. The benefits include: 

Risk Management

Carbon disclosures help organizations identify and assess climate-related risks and vulnerabilities. By understanding their carbon emissions and exposure to climate-related challenges, companies can develop effective risk management strategies to mitigate potential impacts.


Carbon disclosures enhance transparency by providing clear and comprehensive information about an organization's carbon footprint and emissions. This transparency allows stakeholders, including investors, customers, and the public, to make informed decisions and hold companies accountable for their environmental impact.

Investor Confidence

Carbon disclosures instill investor confidence by providing them with critical information to assess the sustainability performance of companies. Investors increasingly consider environmental factors, including carbon emissions, as key indicators of long-term value and risk. 

Transparent carbon disclosures allow investors to evaluate climate-related risks and opportunities, leading to better-informed investment decisions.

Driving Sustainable Practices

Carbon disclosures serve as a catalyst for driving sustainable practices within organizations. By measuring and reporting carbon emissions, companies gain insights into areas where improvements can be made, such as energy efficiency, renewable energy adoption, supply chain optimization, and waste reduction. 

These disclosures encourage companies to implement innovative solutions and adopt sustainable practices to reduce their carbon footprint.

Reputation and Stakeholder Engagement

 Carbon disclosures contribute to building a positive reputation and fostering stakeholder trust. By openly reporting carbon emissions and demonstrating commitment to reducing environmental impact, companies can enhance their reputation as responsible and sustainable entities. Transparent disclosures also encourage stakeholder engagement, dialogue, and collaboration on climate-related initiatives.

Minimum can help organizations to understand their existing carbon output, and create plans to mitigate climate related risks in the future.  Our Emissions Data Platform seamlessly collects and processes emissions data from every corner of your organization and supply chain - no matter the format. Making it the ideal platform for emissions audits and all-round business intelligence. 

Learn more about how Minimum's Emission Data Platform can help to power you all the way to Net Zero today.  

FAQs about Sustainable Finance Disclosure Regulation

What is the difference between SFDR and EU Taxonomy?

The SFDR (Sustainable Finance Disclosure Regulation) and the EU Taxonomy are two distinct regulatory initiatives introduced by the European Union to promote sustainable finance and facilitate the transition to a low-carbon and sustainable economy. While they are related and complementary, they serve different purposes and focus on different aspects: 

  • SFDR: primarily focuses on enhancing transparency and disclosure of sustainability-related information by financial market participants, including asset managers, insurance companies, pension funds, and financial advisors. 
  • EU Taxonomy: aims to establish a framework for classifying “green” or “sustainable” economic activities executed in the EU.

Is ESG regulated in the UK?

Environmental, Social, and Governance (ESG) factors are regulated in the United Kingdom.  For example, the Financial Conduct Authority (FCA) requires asset managers and institutional investors to integrate ESG factors into their investment decision-making and disclose information on their ESG policies and practices.