Following the publication of the proposed revision of SFDR on 20 November 2025, the European Commission launched a public consultation, open from 15 December 2025 to 6 April 2026 (here WeeFIn’s answer). A PRI study conducted between November 2025 and January 2026 shows that 75% of signatories who responded to their questionnaire on SFDR 2.0 (43 stakeholders) are satisfied or very satisfied with the Commission's proposal. To better understand the position of market participants regarding these future regulatory developments, WeeFin conducted an analysis of the main emerging trends from their consultation responses:
The introduction of a minimum threshold of 70% has generally been well received by financial stakeholders. However, clarification of calculation methods is still expected, particularly from stakeholders operating in real estate and infrastructure funds (DGB, ZIA) as well as fund-of-funds (Allianz).
→ The exclusions on hydrocarbons and coal within the Transition category are a matter of debate. Some stakeholders argue that these highly emitting sectors require significant financing in order to begin or continue their transition, and that these exclusions would deprive them of financing opportunities (Amundi, Franklin Templeton, Allianz, GBIC, France Assureurs).
→ Financial stakeholders are also awaiting clarification on the definition of the credibility of transition plans (FIR, Mirova, CECA). Specific indicators could be introduced to ensure the transition of the entities concerned (European Public Real Estate Association).
→ Real estate and infrastructure funds are also awaiting details on how exclusions could apply to their types of investment (ZIA, DGB). Some stakeholders (Eurosif, Mirova, France Assureurs) also recommend the introduction of criteria specific to different asset classes.
Several stakeholders are concerned about the scope of this category, which is considered too broad and insufficiently discriminating (FIR, Association of Real Estate Funds, Mirova, CECA). FIR highlights the need to introduce indicators to measure company performance, as well as more clearly defined engagement strategies.
Views are rather mixed regarding the removal of the obligation to publish PAIs at the entity level. On one hand, its removal is welcomed by stakeholders, as it reduces reporting complexity and simplifies procedures compared to CSRD reporting (Allianz). This reform is particularly welcomed by real estate and infrastructure fund stakeholders (ZIA, DGB) as well as banking stakeholders (CECA). On the other hand, its absence raises concerns about whether entities will adequately conduct an analysis of their negative environmental impacts (FIR, Eurosif, Mirova, France Assureurs). FIR therefore recommends retaining PAI reporting at the entity level while reducing the number of required indicators.
This duality is also reflected in the PRI study, which reveals that while 82% of respondents are satisfied with the removal of the obligation to publish PAIs at the entity level, 55% nonetheless expect a minimum number of indicators to be maintained at the entity level.
Many stakeholders are calling for the RTS to be finalised before the SFDR 2.0 transition period begins, indicating that the revision of SFDR cannot proceed without the full publication of the RTS.
Several European labels (FNG, Nordic Swan, Towards Sustainability, LuxFlag) are calling for the introduction of a specific mention for European labels that already impose particular requirements regarding investments, exclusions, or reporting. This view is also shared by banking stakeholders (FBF).
The new scope of application chosen by the Commission does not find broad support. Several stakeholders are calling for structured products and mandates to be included (FIR), and an opt-out option for professional investors is also mentioned (ZIA, Franklin Templeton, Allianz, FBF). The inclusion of sovereign "use of proceeds" bonds is also a matter of debate. Some stakeholders welcome the inclusion of sovereign bonds in the Transition and Sustainable categories but criticise the restriction to "use of proceeds" instruments (FBF, GBIC).
Data providers and insurance stakeholders (Iceberg Datalab, AMICE) are questioning the consequences of the reduced scope of SFDR application on the volume of available data. Banking stakeholders (FBF) are therefore calling for the use of estimates to fill data gaps, particularly for small companies.
As in the previous consultation, many stakeholders are questioning how this revision aligns with the broader sustainable finance regulatory landscape, particularly with MiFID II and the IDD, as well as the ESMA guidelines on fund names. Stakeholders are therefore seeking further clarification to avoid any overlap in the expected reporting obligations.
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