Sustainability-risk policies only need to cover portfolio management activities, not the firm’s own balance-sheet investments. But within portfolio management, all investment decisions must be included for Article 4 PAIs.
Should the “information about the policies on the integration of sustainability risks in the investment decision-making process” of the financial market participant be restricted to investments affected by other Articles of SFDR (such as Article 6 SFDR) or should this be understood in a wider sense covering all investment decisions?
The scope of the disclosures 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)
