EU Commission Proposal for a Reviewed Sustainable Finance Disclosures Regulation (SFDR)

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Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt EU Commission Proposal for a Reviewed Sustainable Finance Disclosures Regulation (SFDR) The Authority would like to draw your attention that the European Commission has proposed a set of amendments to the Sustainable Finance Disclosure Regulation (SFDR). The proposed changes are designed to address current shortcomings, making the rules simpler, more efficient, and better aligned with market realities. The revised rules will be more retail￾friendly and usable for companies. A comprehensive review of the SFDR by the Commission has shown that the current framework results in disclosures that are too long and complex, making it difficult for investors to understand and compare the environmental or social characteristics of financial products. Moreover, the SFDR has effectively been used as a de facto labelling system, causing confusion – particularly for retail investors – and increasing the risk of greenwashing and mis-selling. As a result, the regulation has not fully met its objectives to help the EU financial sector allocate capital for Europe's sustainable priorities. The amended rules proposed by the EU Commission will result in simpler and more usable information for investors, enabling them to make better informed choices. Providers of financial products will see a reduction in disclosure requirements, enabling them to cut costs. The proposed changes aims to bolster the EU's leading role in sustainable finance and the competitiveness of its financial sector. Moreover, they will facilitate an increased participation of retail investors in EU capital markets, in line with the objectives of the Savings and Investments Union (SIU) and help boost the flow of funds towards sustainable objectives. Key Elements of the Proposal a. Simplified Disclosures The Commission proposes to delete entity-level disclosure requirements for Financial Market Participants (FMPs) regarding principal adverse impacts indicators. The aim is to streamline corporate disclosures in the sustainable finance framework, addressing current overlaps between the Corporate Sustainability Reporting Directive (CSRD) and the SFDR. This aligns with the Commission's Omnibus I simplification package from February 2025 and significantly reduces the implementation costs associated with the SFDR. In the future, only the largest FMPs subject to the updated thresholds under the CSRD will need to disclose their impacts on the environment and society. Removing entity-level disclosures from the SFDR significantly cuts reporting requirements and costs associated with collecting data 21 November 2025

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Triq l-Imdina, Zone 1 Central Business District, Birkirkara CBD 1010 +356 2144 1155 communications@mfsa.mt www.mfsa.mt across a wide range of environmental, social and governance (ESG) topics and removes duplications. The Commission is also proposing a significant reduction in product-level disclosures, limiting them to data that is available, comparable, and meaningful. Focused on the key criteria underpinning the proposed product categories (see point b. below), this will give providers more clarity and certainty on how to design and present the sustainability characteristics or objectives of their products, making them more relevant and comparable for investors. The revised disclosures will also be more retail friendly, helping retail investors to quickly and easily understand the sustainability features of financial products. b. A Clear Categorisation System Based on a wide consensus in stakeholder feedback, the Commission is proposing a simple categorisation system for financial products making ESG claims. It will comprise three categories with clear criteria, building on existing market practices that have been informed by the latest regulatory guidance. The categories will simplify the investment journey of retail investors and help them make informed investment decisions. Broadly, the categories will be:

• ‘Sustainable category': products contributing to sustainability goals (e.g. climate,
  environment or social goals), such as investments in companies or projects that are already meeting high sustainability standards;
• ‘Transition category': products channeling investments towards companies and/or
  projects that are not yet sustainable, but that are on a credible transition path, or investments that contribute toward improvements in e.g. climate, environment or social areas;
• ‘ESG basics category': other products that integrate a variety of ESG investment
  approaches but do not meet the criteria of the above-mentioned sustainable or transition investment categories (e.g. focusing on best-in-class performers on a given ESG metric, pursuing financial returns while excluding the worst ESG performers). Categorised products would need to ensure that a high portion of investments (70% of the portfolio) supports the chosen sustainability strategy and exclude from all their portfolio investments in harmful industries and activities, for example companies in violation of human rights standards as well as those involved in tobacco, prohibited weapons and fossil fuels above certain limits. ESG claims in names and in marketing documentation will be reserved for categorised products – this is a key step to fight greenwashing and boost trust in sustainable investments. The Commission proposal will now be submitted to Parliament and Council for their deliberation.