No. Simply integrating sustainability risks is not enough. The product must actively promote environmental or social characteristics.
Is referencing or integrating sustainability risks enough for Article 8 to apply, even if the product does not advertise any ESG characteristics?
Financial products that fall under Article 8 may pursue reduction of negative externalities caused by the underlying investments, such as principal adverse impacts on sustainability factors referred to in point (a) of Article 7(1) of Regulation (EU) 2019/2088. In addition, as confirmed by Article 6 of Regulation 2020/852, nothing prohibits financial products that fall under Article 8 to be, in part, invested in ‘sustainable investments’ as defined in point 17 of Article 2 of Regulation (EU) 2019/2088. On the other hand, integration per se of sustainability risks, as defined by point 22 of Article 2 of Regulation (EU) 2019/2088, is not sufficient for Article 8 to apply.
European Commission
