Article 4 PAI disclosures must cover all investments made through portfolio management, not the firm’s own-account holdings.
When it comes to entity-level disclosures in Article 4 should those disclosures relate only to financial products in scope of SFDR, or should those disclosures also relate to other types of instruments invested in by the financial market participant (e.g. structured bonds)? Should those disclosures also deal with own investments made on financial market participant’s own account?
The scope of the disclosures under Article 4(1)(a), 4(3) or 4(4) SFDR is limited by the definitions of “financial market participant” in Article 2(1) SFDR, (i.e. credit institutions and investment firms should only cover their portfolio management activities and e.g. not their own account). Within this scope, FMPs have to consider all investment decisions for the disclosures under Article 4(1)(a), 4(3) or 4(4) SFDR.
European Supervisory Authorities (ESAs)
