Finalised SFDR 2.0 proposal: the Commission’s proposal and what it means for funds marketed in the EU
On 20 November 2025, the European Commission presented its final proposal for a comprehensive reform of the SFDR framework, also referred to as “SFDR 2.0”. The SFDR framework regulates how asset managers and other financial firms must disclose sustainability information to their investors and clients. The Commission’s proposal departs from today’s transparency-only approach and introduces three new product categories with substantial minimum criteria, as well as a requirement that at least 70% of investments must align with the fund’s sustainability theme (so-called eligible investments). Previously proposed exemptions – such as an opt-out for certain AIFs and the removal of requirements to disclose so-called PAI information (principal adverse impacts) – have been rolled back, meaning, among other things, that all financial market participants must categorise their financial products. The new rules are expected to apply no earlier than 2028.
Please read our more detailed review of the Commission’s proposal here.
Contact:
Carl Johan Zimdahl, Partner
carl.johan.zimdahl@msa.se
