ESMA Thematic Notes on Clear, Fair and Not Misleading Sustainability-Related Claims – Third Note on Impact Claims and Fourth Note on Transition Claims

TO
: Regulated Entities:
i. Cyprus Investment Fund Managers (‘CyIFMs’ or ‘all
Managers’):
a. Cyprus UCITS Management Companies and Self-Managed Cyprus UCITS (‘CyUCITS MCs’) b. Cyprus Alternative Investment Fund Managers and Self- Managed Cyprus AIFs (‘CyAIFMs’)
c. Sub-Threshold Cyprus Alternative Investment Fund
Managers and Self-Managed Cyprus AIFs (‘sub- threshold CyAIFMs’)
ii. Cyprus Investment Firms (‘CIFs’)
FROM
: Cyprus Securities and Exchange Commission DATE : 27 October 2026 CIRCULAR NO. : C809 SUBJECT : ESMA publication of thematic notes on clear, fair & not misleading sustainability-related claims – Third and Fourth Notes:
Impact Claims and Transition Claims

1. Following the publication of Circular C752, informing Regulated Entities of the issuance by ESMA of the Second Thematic Note on ESG Strategies, the Cyprus Securities and Exchange Commission (‘CySEC’) wishes to bring to the attention of Regulated Entities to the ‘Third Note on Impact Claims’ and the ‘Fourth Note on Transition Claims’ which were published on October the 12th 20261 .

2. CySEC urges Regulated Entities to ensure that they remain up to date with the publication of such thematic notes and expects that the guidance provided in the Thematic Notes is considered when complying with their relevant ESG obligations.

Sincerely,

Loukas Lagoudis
Vice Chairman
Cyprus Securities and Exchange Commission

[1] These Thematic Notes issued by ESMA, are relevant to the guidance issued by CySEC on Sustainable Finance, through circulars C704 and C683 addressed to CyIFMs and CIFs respectively.