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In response to the European Commission's consultation on the revision of SFDR (opened in December 2025, closed on 6 April 2026), WeeFin has published its official position. Here are the key takeaways.
On exclusions, the obligation to exclude new fossil fuel projects should be extended to Article 8 funds, to avoid over-classification. WeeFin suggests raising the coal exclusion threshold from 1% to 5% rather than removing this requirement altogether.
On the new product categories, transition and impact are welcome additions, but the notions of credible transition plan, engagement and theory of change remain too vague, creating exposure to greenwashing risks.
On investment thresholds, the 30% of assets not subject to the fund's primary objective should not be allowed to contradict that objective, a clarification currently absent from the proposal.
On asset classes, real estate and infrastructure remain insufficiently addressed, as PAB/CTB criteria are not well suited to these investments.
On the EU Taxonomy, the substitution mechanism (15% Taxonomy alignment replacing 70% objective alignment) is considered insufficient and potentially misleading, particularly for Article 7 transition funds.
On PAI reporting, further guidance is needed on how materiality should be assessed and which indicators should be mandatory, especially on social and governance issues.
Finally, WeeFin calls for stronger coherence between SFDR 2.0, the ESMA framework and ESRS standards to avoid confusion and reporting gaps.
📄 Read WeeFin's full response to the SFDR 2.0 consultation: here.
