On 20 November 2025, the European Commission
(the Commission) formally published
its
legislative proposal to amend the
Sustainable Finance Disclosure
Regulation (SFDR), the PRIIPs KID
Regulation and repeal the SFDR
Delegated Regulation (SFDR 2.0). The
publication follows a leaked draft of the amendments in circulation
earlier in November.
Upon implementation, SFDR established a disclosures framework
for financial market participants (FMPs) regarding
how they integrate and disclose environmental, social and
governance (ESG) factors, which was further
amended and supplemented by, inter alia, the Taxonomy
Regulation and the SFDR Delegated Regulation. SFDR 2.0
represents a significant overhaul of the current framework and
signals the evolution of SFDR into a product categorisation-based
framework. In this advisory we will outline the key changes
proposed by the Commission which are underpinned by two central
themes: