went into force in March 2021. SFDR had highly ambitious objectives—not only preventing fund “greenwashing” but also shifting capital in support of the EU’s “Green Deal” to become carbon neutral by 2050. Three years later, it is worth asking whether SFDR has achieved those objectives. Or whether it has simply become a complex and ever-changing labeling exercise.As a starting point, it is still unclear exactly how to categorize a sustainable fund under SFDR.
· “94% of respondents agree that opting for a disclosure framework at the EU level is more effective than national measures at Member State level.” It also found that 83% of respondents felt that “the SFDR is currently not being used solely as a disclosure framework as intended, but is also being used as a labelling and marketing tool .” That said, there was no consensus on whether to split the categories in a different way than Articles 8 and 9 or to convert them into formal product categories by clarifying and adding criteria to the underlying concepts.
“‘’sustainable investment’ means an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to...