How do I complete the sovereign and real estate PAI indicators if I have no such investments?

SFDR Delegated Regulation (EU) 2022/1288, Annex I, Table 1
November 17, 2022

In simple words

If your fund or firm has no investments in sovereigns or real estate, you should leave the corresponding rows for those indicators in Table 1 of Annex I blank or filled with zero values. All other indicators that are relevant to your portfolio must still be completed. The goal is to show clearly that you have no exposure in these asset classes rather than trying to remove the rows.

Official question

Should an FMP still disclose the indicators applicable to investments in “sovereigns and supranationals” and “real estate assets” if the FMP makes no investments in sovereigns, supranationals and real estate assets?

Official answer

If a financial market participant makes no investment decisions resulting in investments in sovereigns or real estate, then the rows in the template in Table 1 of Annex I corresponding to indicators for sovereigns and real estate should be left empty or with zero values. All the other indicators and fields in the template in Table 1 of Annex 1 should be completed by such a financial market participant.

Answered by

European Supervisory Authorities (ESAs)

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