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SFDR Simplified: Key Takeaways from the European Commission’s Revised Sustainable Finance Disclosure Regulation Proposal

Date: November 20, 2025
Authors: Douglas Bryden, Elisabeth Overland, Theresa Kreft, Léa Bareil, Charlotte Aspin, Emily Strand, Eden Elder, Leila Symonds

Background

The European Commission now proposes changes to the SFDR. The SFDR was set in 2021 to help financial intermediaries. It guides them to share clear facts about Environmental, Social, and Governance concerns. Critics called the SFDR too complex, inefficient, and prone to greenwashing. The Commission wants simpler rules and a stronger system.

Drivers for Reform

• The fund labels acted like clear tags. This worry led to false claims.

• Some rules came from the Corporate Sustainability Reporting Directive, adding extra work. Rules overlapped and confused users.

• Finding accurate ESG data was hard. This made meeting the rules difficult.

• High admin work slowed down businesses. The new plan aims to cut costs.

The Commission seeks fewer burdens and clearer facts for investors.

Major Proposed Changes

1. Eliminate entity-level Principal Adverse Impact (PAI) disclosures.
   The focus now is on product-level reports for products in the Transition (Art. 7) and Sustainable (Art. 9) groups.
   This move may cut annual costs by about 25%.

2. Simplify product-level disclosures.
   New templates are short and list key topics only.
   They give easy information for retail investors.

3. Narrow the scope.
   Financial advisers and portfolio managers are not bound by SFDR.
   This change lowers compliance work for these groups.

4. Remove the “sustainable investments” idea.
   The vague term and tests like “do no significant harm” are dropped.
   The measure makes the rules simpler.

5. Introduce three revised product categories with ESG labels.
   The rules now use labels that meet market demands and fix past issues.

   • Transition Category (Article 7)
   This targets funds that help entities move toward sustainability.
   It avoids tobacco, controversial weapons, human rights violators, and unchecked fossil fuel plans.

   • ESG Basics Category (Article 8)
   This covers funds that add ESG factors without clear sustainability goals.

   • Sustainable Category (Article 9)
   This is for funds with firm sustainability goals that match the EU taxonomy.
   Each fund must meet at least a 70% compliance standard.

Implications

The Commission’s changes aim to make ESG disclosures plain. They want to lower costs and give clear labels. This builds trust in sustainable finance. The focus on product details brings harmony to EU rules and cuts extra reporting.

Conclusion

The new SFDR updates show the European Commission’s wish for simple rules and strong transparency. Investors and market players can soon face a clearer, unified system. This target will help sustainable finance grow in Europe.

For detailed legal analysis and ongoing updates on the SFDR revisions, stay connected with our expert insights.

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