ESMA_QA_2663

Status: ✅ Answer Published

Link to ESMA Q&A tool: https://www.esma.europa.eu/publications-data/questions-answers/2663

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Regulatory Context

Regulation : SFDR

Level 1 Regulation: Regulation (EU) 2019/2088 - Sustainable Finance Disclosure Regulation (SFDR)

Level 2 Regulation: No information available

Level 3 Regulation: No information available

Topic: Disclosures

Subject Matter: Disclosure obligations under Article 9(3)

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Question

Submission Date: 10 October 2025

The European Commission clarified in Q&A II.1 that, pursuant to Article 9(3) of SFDR, financial products tracking a Paris-aligned Benchmark (PAB) or a Climate Transition Benchmark (CTB) are deemed to make sustainable investments. Based on this clarification, can such financial products hold investments eligible under PAB/CTB requirements, which may, however, not qualify as sustainable investments within the meaning of Article 2(17) of SFDR under the relevant financial market participant’s own methodology? Can the clarification provided by Q&A II.1 also be extended to:

• Financial products disclosing under Article 9(3) of SFDR that apply all requirements of Commission Delegated Regulation (EU) 2020/1818 for PABs/CTBs, but that do not passively track such indices?
• Other types of financial products that have a reduction in carbon emissions as their objective and disclose under Article 9(3) of SFDR (i.e. without tracking a PAB/CTB or applying the requirements applicable to these indices)?

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ESMA Answer

Answer Date: 10-10-2025

No answer has been published yet for this question.

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This document was automatically extracted from the ESMA EMIR Q&A database.