The CSSF would like to bring to the attention of Financial Market Participants (FMPs) that the amended SFDR RTS has entered into force on 20 February 2023. These amendments require precontractual and periodic transparency obligations in relation to Taxonomy-aligned fossil gas and nuclear energy-related activities for financial products disclosing under Articles 8 and 9 of SFDR.

Regarding precontractual documents, FMPs must provide the disclosure information in the format of the templates outlined in the annexes of the amended SFDR RTS for:

  • Investment funds launched after the entry into force of the amended SFDR RTS; and
  • Existing investment funds that introduce changes in the prospectus/issuing document after the entry into force of the amended SFDR RTS.

With the purpose of simplifying the CSSF review process, in cases where changes to the prospectus/issuing document are limited to the usage of new templates outlined in the appendices of the updated SFDR RTS, FMPs must confirm in the application file submitted to the CSSF that (i) they have utilized the new templates and (ii) no further modifications have been made.

Regarding periodic reports, FMPs must present the periodic disclosure information in the format of the templates set out in the annexes of the amended SFDR RTS for annual reports of investment funds issued after the amended SFDR RTS comes into effect, regardless of the financial year-end of the investment funds.

Please feel free to contact our investment management team should you have any questions concerning the above.