Myth 1: SFDR 2.0 introduces “unofficial” categories with no article numbers
Reality:
The official proposal does introduce three legal product categories in the regulation itself:
- Article 7: Transition products
- Article 8: ESG Basics products
- Article 9: Sustainable products
These replace the old Article 8/9 “quasi-labels” entirely. The new structure is clear, formal, and article-based.
Myth 2: Professional-investor funds can fully opt out of SFDR
Reality:
There is no opt-out for professional-only funds in the official proposal. SFDR still applies to all in-scope financial market participants.
What’s voluntary is choosing a label (Articles 7–9), not participating in SFDR.
There is only a narrow carve-out for closed-ended funds created before the new rules apply, not a broad exemption.
Myth 3: SFDR 2.0 removes all PAI requirements
Reality:
- Entity-level PAI reporting is deleted (Articles 4 & 5 removed).
- Product-level adverse impact assessment remains, embedded within each category’s rules.
Funds still need to identify material negative impacts and explain how they address them.
Myth 4: Taxonomy disclosures are abolished under SFDR 2.0
Reality:
Taxonomy alignment becomes voluntary, not abolished.
Two important features remain:
- Products with 15%+ Taxonomy alignment automatically satisfy the “positive contribution” 70% rule.
- EU Climate Benchmarks remain a pathway to qualify.
The Taxonomy becomes a tool, not a requirement.
Myth 5: SFDR removes advisers and portfolio managers from scope
Reality:
Partially true and this is in the proposal.
The proposal removes financial advisers from SFDR scope, and portfolio management is no longer treated as a product type under the labelling framework.
Myth 6: Impact terminology will be heavily restricted.
Reality:
Naming rules do restrict the use of “impact.”
Only certain Article 9 Sustainable products that meet extra impact criteria may use “impact” in fund names or marketing. Other funds cannot use impact terminology.
This is explicitly written into the new naming rules.
Myth 7: The new rules will apply to 2026 disclosures.
Reality:
No, the proposal is not yet law. Once adopted, it applies 18 months after entry into force.
On top of that:
- All Level-2 RTS (templates, DNSH RTS, Taxonomy RTS, PAI RTS) have been de-prioritised until at least 1 October 2027
- This means no impact on 2026 disclosures, and full implementation likely post-2027.
What SFDR 2.0 actually changes (confirmed)
- The Article 8/9 regime is abolished and replaced with Articles 7, 8, 9
- New categories must meet:
- 70% minimum alignment with the sustainability/transition strategy
- Mandatory exclusions (weapons, tobacco, coal/lignite; fossil-fuel rules vary by category)
- Adverse impact assessment & mitigation
- Entity-level PAI and remuneration disclosures are deleted
- Only categorised products can use ESG/sustainable/impact terminology in names.
- Templates are simplified and standardised
- Two-page maximum for labelled funds.
- Taxonomy becomes voluntary, not removed
- Implementation depends on RTS; delayed until 2027+
What’s confirmed in the Level-2 Annex
All technical standards required for implementation are delayed until at least 1st October 2027:
- PAI RTS
- Article 8/9 templates
- DNSH RTS
- Taxonomy disclosure RTS
- Website & periodic RTS
This reinforces that SFDR 2.0 implementation is not imminent.
