Financial services · Checklist

Selling financial products or managing funds in the EU requires SFDR sustainability-risk disclosure; ESG claims are bound by Articles 8/9 and cross-referenced with the CSRD and the EU Taxonomy.

Tick items for internal review; triggers and thresholds depend on the entity, product classification and Member State application. See the industry dossier and follow the links for the legal source.

Industry-specific duties

Product-level sustainability disclosure (SFDR Article 6) Disclose sustainability risks and their impact on returns in prospectuses and periodic reports. Trigger:Selling financial products to EU investors, or providing investment/insurance advice · Evidence:Sustainability risk disclosures in product documents and periodic reports; website information · Timing:Ongoing from 2021-03-10 Source:Reg (EU) 2019/2088, Article 6
Principal adverse impacts (PAI) statement Publish a principal adverse impacts statement on the website and update it annually. Trigger:Financial market participants with more than 500 employees (financial advisers from 2022-08) · Evidence:PAI statement (using the indicators set out in the RTS) · Timing:Annually from 2023-06-30 Source:Reg (EU) 2019/2088, Article 4; DelReg (EU) 2022/1288
Article 8/9 product classification and periodic disclosure Funds promoting environmental or social characteristics (Article 8) and funds with sustainable investment as their objective (Article 9) must make product- and entity-level disclosures. Trigger:Funds/products claiming ESG characteristics or a sustainable investment objective · Evidence:Product classification, portfolio alignment information, website and periodic disclosures · Timing:Phased from 2021; RTS from 2023-01-01 Source:Reg (EU) 2019/2088, Articles 8–11
EU Taxonomy alignment disclosure Disclose the proportion of Taxonomy-aligned turnover, capital expenditure and operating expenditure. Trigger:Financial institutions within the scope of the CSRD/NFRD, or issuing green bonds · Evidence:Taxonomy alignment ratios (turnover/capital expenditure/operating expenditure) · Timing:Phased from 2022 Source:Reg (EU) 2020/852; DelReg (EU) 2021/2178
Sustainability reporting (CSRD) Large or listed financial institutions must report sustainability information in accordance with the ESRS and obtain assurance. Trigger:Large or listed financial institutions (thresholds see Omnibus I) · Evidence:ESRS sustainability statement and third-party assurance · Timing:Phased from FY2024; thresholds adjusted by Dir (EU) 2026/470 Source:Directive (EU) 2022/2464; Dir (EU) 2026/470

Duties by regulation

Sustainable Finance Disclosure Regulation (SFDR) Regulation (EU) 2019/2088 In force Key date:2019 (applies from 2021-03-10)

Publish a sustainability risk policy Disclose on the website the policy on integrating sustainability risks in investment decisions. Trigger:As a financial market participant · Evidence:Website policy disclosure · Timing:Ongoing
Pre-contractual and periodic disclosure of sustainability risk integration Explain in pre-contractual documents how risks are integrated and the assessed impact on returns. Trigger:Providing financial products or investment advice · Evidence:Pre-contractual disclosures, periodic reports · Timing:Ongoing
Disclose the characteristics or objectives of Article 8 / 9 products Products promoting environmental or social characteristics or targeting sustainable investment must make additional disclosures on methods and indicators. Trigger:Product falls within the scope of Article 8 or Article 9 · Evidence:Product disclosure documents, index and indicator descriptions · Timing:Ongoing

EU Taxonomy Regulation (EU) 2020/852 + DA (EU) 2021/2139 In force Key date:2020

Determine the environmental characteristics of activities under the Taxonomy Determine whether an economic activity substantially contributes to climate mitigation/adaptation and does no significant harm. Trigger:Entities subject to CSRD/financial market rules · Evidence:Taxonomy-aligned disclosure (share of turnover, CapEx, OpEx) · Timing:Annual reporting

CSRD Corporate Sustainability Reporting Directive Directive (EU) 2022/2464 In force Key date:phased application

Prepare sustainability reporting in accordance with ESRS Include climate and other sustainability information in the management report and carry out a double materiality assessment. Trigger:Large undertakings / listed SMEs meeting the size thresholds (thresholds raised by 2026/470) · Evidence:Sustainability statement, double materiality assessment, limited assurance verification · Timing:Phased by financial year; simplified ESRS from FY2027

Omnibus I Amendment Directive (EU) 2026/470 In force Key date:2026-03-18 entry into force

Re-assess coverage against the new thresholds The reporting threshold is raised to more than 1,000 employees and reporting content is simplified by around 60% of data points. Trigger:Companies close to the original CSRD thresholds · Evidence:Assessment based on employee numbers and revenue · Timing:After 2026/470 enters into force

EU Green Bond Standard Regulation (EU) 2023/2631 In force Key date:2024-12

Use of the European Green Bond label must meet the standard Issuance must meet taxonomy alignment, allocation of proceeds and external review requirements. Trigger:Issuing and marketing a bond as an EU green bond · Evidence:Allocation report, external review, impact report · Timing:After 2023/2631 enters into force

Basis: Industry and regulation duty entries compiled by this site; source numbers checked against CELLAR. This page is a compliance guide; the official text and the competent authority's interpretation prevail. Entries marked "under consideration" or "draft" may change.

Financial services · Checklist

Industry-specific duties

Duties by regulation

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