Overview
- Proposal replaces the Article 8/9 construct with Sustainable, Transition and ESG Basics categories, each requiring at least 70% of assets to follow the stated strategy and applying category-specific exclusions such as fossil-fuel limits for higher-ambition products.
- Categorised products must use concise, standardised pre-contractual, website and periodic disclosures capped at two pages, while non-categorised funds keep a baseline statement with tightly limited voluntary disclosures under a new Article 6a.
- Strict naming and marketing controls would confine sustainability terms to qualifying products, bar sustainability claims for non-categorised funds and reserve “impact” language for products that pass an additional impact test.
- Entity-level principal adverse impact statements and related remuneration-policy disclosures would be deleted to align with CSRD, with product-level PAI reporting retained for Sustainable and Transition products.
- The scope would exclude portfolio management and investment advice, provide only narrow grandfathering for certain closed-ended AIFs and foresee an 18‑month implementation and a 2027–2028 start-up phase before the envisaged late‑2028 application.