ARTICLE · 12 NOVEMBER 2026

SFDR 2.0 Update

Arthur Cox

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The European Parliament has adopted its negotiating position on SFDR 2.0, proposing to replace the current Article 8 and Article 9 framework with three voluntary product categories: Transition, ESG Basics, and Sustainable. Each category would require a minimum 70% investment threshold alongside specific criteria, with Parliament supporting an opt-out for certain alternative investment funds marketed exclusively to professional investors.

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Dara Harrington

Stephanie Hanrahan

Christopher O'Reilly

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As we previously reported, the European Commission (the “Commission”) published its final proposal for a regulation amending the Sustainable Finance Disclosure Regulation (“SFDR”) (PDF, 576 KB) on 20 November 2025 (“SFDR 2.0”).

Key takeaways

SFDR 2.0 proposes replacing the existing Article 8 and Article 9 designations with three voluntary categories: Transition, ESG Basics and Sustainable

Each of the three main categories would be subject to a minimum 70% investment threshold, alongside category-specific criteria and exclusions

Parliament supports an opt-out from the categorisation regime for AIFs marketed exclusively to per se MiFID professional investors, subject to certain conditions

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