ESMA_QA_2662
10/10/2025
Subject Matter
Investment firms’ SFDR disclosure obligations
    In the case where a financial market participant, such as a fund manager (delegator), delegates the portfolio management of a fund to an investment firm (delegatee), is the delegatee investment firm subject to the same SFDR disclosure obligations for the portfolio management it performs for that fund as when it deals with discretionary portfolio management mandates with end investors?
    Status: Forwarded to EC/Public Consultation/Other

    Additional Information

    Level 1 Regulation
    Regulation (EU) 2019/2088 - Sustainable Finance Disclosure Regulation (SFDR)
    Additional Legal Reference
    Art 2.1(b)
    Topic
    Disclosures