Please clarify the scope of ‘financial information’ to which Article 19(1b) of the Prospectus Regulation applies.

Article 14 of Regulation (EU) 2023/2631 on European green bonds (‘EuGB Regulation’) requires certain issuers to publish a prospectus approved under Regulation (EU) 2017/1129 (the ‘Prospectus Regulation’) in order to use the designation of ‘European Green Bond’ or ‘EuGB’. Article 10 of the EuGB Regulation sets out the requirements relating to the completion of an EuGB factsheet, while Article 15 sets out requirements relating to the publication of the EuGB factsheet.

In this regard, is it possible to publish the EuGB factsheet prior to the publication of a prospectus approved under the Prospectus Regulation? Moreover, is it possible to advertise a European Green Bond prior to the approval and publication of the prospectus? Please clarify the meaning ‘use of the designation’ in this context.

We have been discussing a number of queries submitted by the local industry regarding practical difficulties when applying the definitions of micro, small and medium-sized enterprises as per Article 3 points (60), (63) and (64) of the DORA Regulation to self-managed AIFs and UCITS. We would like to obtain further clarification on the correct and proportionate interpretation of “annual turnover”, “total assets” and “employees” in the context of self-managed AIFs and UCITS.

Are AIFMs permitted to hold client money, taking into account also the wording of Article 6(4)(b)(ii) of the AIFMD?

Will the situation change in light of the legislative amendments introduced following the AIFMD Review (Directive 2024/927/EU)?

Are AIFMs allowed to delegate portfolio or risk management to non-supervised undertakings established outside of the EU?