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_As you may already know, the Luxembourg financial market participants are getting prepared to meet the first compliance deadline of 10 March 2021 of EU Regulation 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”).
At present, we are awaiting certain guidance that will be issued by the Commission in its Level 2 Regulatory Technical Standards, but the Level 1 requirements under SFDR must be complied with notwithstanding this delay. These include the requirement for financial market participants to categorise their financial products, and make consequential disclosures in offering documentation and their website.
In particular, we draw your attention on the necessity for AIFM and UCITS management companies to update prospectuses and offering documents with SFDR disclosures regardless of the financial product categorisation. Where a financial market participant has a CSSF authorised product, they will also need to file their prospectus changes with the CSSF. To facilitate their submission, the CSSF has implemented a specific SFDR fast track procedure available for UCITS prospectuses, Part II UCI offering documents and SIF offering documents. A submission for CSSF visa stamp must be done by 28 February 2021 at the very latest in order to meet the 10 March 2021 deadline.
Our Investment Funds Practice Group would be delighted to guide you through the SFDR staggered steps and to provide you with legal assistance in implementing these new requirements.