CSSF SFDR data collection exercise
01/06/23
In brief
The Commission de Surveillance du Secteur Financier (CSSF) has launched a data collection exercise on sustainability-related disclosures to be reported in the eDesk Portal of the CSSF.
The new requirement applies to all investment funds (Luxembourg domiciled UCITS, regulated and unregulated AIFs - including ELTIFs) and Institutions for Occupational Retirement Provision (IORPs). The information should be provided by the Investment Fund Manager/IORP on a best effort basis by 15 June 2023 and at the latest by 31 October 2023.
In details
The questionnaire covers a comprehensive set of information (quantitative, binary and qualitative - open - questions) related to pre-contractual disclosures. The aim of the Sustainable Finance Disclosure Regulation (SFDR) data collection is to systematically collect information contained in the precontractual documents and also to obtain confirmation on some more general SFDR related questions going beyond the SFDR precontractual templates.
The information must be provided for:
i. Sub-funds disclosing under SFDR Article 8;
ii. Sub-funds disclosing under SFDR Article 9;
iii. Sub-funds neither disclosing under SFDR Article 8 or SFDR Article 9 (i.e. sub-funds classified as Article 6 according to SFDR).
Under (i) and (ii), the data collection relates to the environmental and/or social characteristics of the sub-funds.
Under (iii), the data collection relates to sustainability risks and adverse impacts pursuant to SFDR Articles 6 and 7.
The reporting can be done either in a standardised file (in Json format) via S3 (Simple Storage Service) for all sub-funds under management or in a manual input via the eDesk portal for each sub-fund.
The CSSF expects information provided to be updated in the case the information provided within the pre-contractual template changes. The current data collection exercise will be extended in the near future to collect information contained in the Principal adverse impact (PAI) statements and in the periodic disclosure templates.
This new requirement generates an additional reporting burden for the Asset managers.
As part of its Managed Services offering, PwC proposes a solution to facilitate the CSSF SFDR reporting by preparing the Json template file to allow the Investment Manager to efficiently comply with the reporting obligation.
The Json file is created based on the EET file (the official FinDatEx data exchange template for ESG data) (either provided by you or prepared by PwC) and a standardised input file to cover the qualitative answers.
Should you be interested in discovering our ESG reporting solutions, please contact Sylvain Di Graci or Christian Heinz who will be pleased to assist you.
