Implementation Of SFDR – The MFSA Establishes A Fast-track Process

The SFDR requires financial market participants and financial advisers to make pre-contractual disclosures to investors on how they integrate ESG factors in their risk and decision-making processes. Amongst other participants, the SFDR will require AIFMs, UCITS management companies and MiFID firms managing third-party funds to ensure that adequate disclosures are included in offering documentation of funds under management.

In view thereof, the MFSA has introduced a fast-track filing process that will apply to revisions of offering documents of Malta-based collective investment schemes to reflect Level 1 text of the SFDR. The fast-track solution enables participants to 'self-certify' their compliance with SFDR and to notify the MFSA accordingly. The notification shall include a number of supporting documents prepared by or on behalf of the scheme (as the case may be, depending on whether the fund is self-managed or third-party managed).