The European Commission announced yesterday that the single delegated act which will include the Regulatory Technical Standards (RTS) supplementing the Sustainable Finance Disclosure Regulation (SFDR), as well as the RTS supplementing disclosures for Article 8 and 9 SFDR products that make environmentally sustainable investments (under Articles 5 and 6 of the Taxonomy Regulation), will be delayed by a further six months to 1 January 2023.

This follows the European Commission’s previous postponement of the SFDR RTS from 1 January 2022 to 1 July 2022 and announcement that all 13 RTS’ will instead be compiled into a single delegated act.

The postponement follows delays in the adoption of the RTS for Taxonomy-related disclosures for Article 8 and 9 SFDR products, the Final Report of which was only recently published on 22 October 2021.

Managers will therefore have additional time to prepare for the more detailed disclosures under the SFDR and the Taxonomy (if relevant), which will be relevant for managers of Article 8 and 9 SFDR products. In addition, for managers who have decided to comply with the principal adverse impact disclosures regime under Article 4 of the SFDR, the first reference period for such disclosures will be from 1 January 2022 to 31 December 2022, in order to make the first website disclosures by 30 June 2023.

Whilst the delay provides additional time for managers to comply, uncertainty remains as to what these final rules will look like. This makes it challenging for managers in determining which SFDR product classification is relevant for their fund and whether they will be able to comply with the relevant disclosure requirements.