ARTICLE · 27 NOVEMBER 2025

SFDR Reform Proposal – Key Changes

Arthur Cox

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On 20 November 2025, the European Commission (the "Commission") published its long-awaited legislative proposal to overhaul the Sustainable Finance Disclosures Regulation ("SFDR").

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Dara Harrington

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On 20 November 2025, the European Commission (the "Commission") published its long-awaited legislative proposal to overhaul the Sustainable Finance Disclosures Regulation ("SFDR"). The reform aims to simplify the regime, address market confusion, and better align disclosure requirements with other EU sustainability frameworks.

A comprehensive review of SFDR by the Commission since 2023 has shown that the current framework results in disclosures that are too long and complex, making it difficult for investors to understand and compare the environmental or social characteristics of financial products.

Proposed changes

New voluntary product categories:
The existing Article 8 and Article 9 designations will be replaced with three new voluntary categories for sustainability-related financial products:

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This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.

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