The CSSF has launched a data collection exercise related to the SFDR. The exercise focuses on the collection of information regarding organisational arrangements of IFMs.

The data collection is necessary for the CSSF to assess the compliance of IFMs with the requirements applicable under SFDR .

The CSSF is requiring Luxembourg-domiciled UCITS management companies, SIAGs, authorised AIFMs, managers of a qualifying venture capital fund registered in accordance with Article 14 of Regulation (EU) No 345/2013 and managers of a qualifying social entrepreneurship fund registered in accordance with Article 15 of Regulation (EU) No 346/2013 to complete a dedicated questionnaire via the launch of a new eDesk module, “SFDR-IFM disclosures” as from 2 February 2023.

The questionnaire must be completed and submitted by an eDesk user linked to the IFM.

The deadline for submission of the questionnaire is 2 March 2023.

IFMs must ensure that the information provided is being kept up-to-date, and can use the “Create update declaration” function under the new eDesk module to allow the amendment of information initially submitted.

The CSSF will communicate further details on timing and practical proceeding of the data collection for the collection of information contained in the PAI statements and in the precontractual and periodic disclosure templates.

The CSSF also reminds industry participants that a Common Supervisory Action exercise (CSA) in relation to sustainability risks and disclosures is currently under discussion at ESMA level, focusing on both SFDR Level 1 and Level 2 provisions as well as the requirements outlined in the ESMA Supervisory Briefing on Sustainability risks and disclosures in the area of investment management.