The long-awaited updated supervisory statement on the
application of the Sustainable Finance Disclosure Regulation
("SFDR") was recently published by the
European Supervisory Authorities
("ESAs"), followed by a meeting between
Irish Funds industry representatives (including Head of our Asset
Management and Investment Funds Department, Tara Doyle) and the
Central Bank of Ireland ("Central Bank")
to discuss implementation issues.
One important clarification arising from the discussions with
the Central Bank relates to the need to further update disclosures
in light of the updated ESAs' supervisory statement and the
Central Bank's spot checks of submissions received. The Central
Bank has indicated an initial view that, for Article 8 and Article
9 SFDR funds, any updates to disclosures informed by the sample
review (including any explicit quantification of Taxonomy
alignment, where relevant) could be incorporated into the filings
they would make to incorporate Level 2