The CSSF has published a communication on SFDR data collection on 24 March 2023 in accordance with its Communication dated 27 July 2022, in which it announces a data collection exercise in relation to the precontractual disclosures on Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”) and Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (“TR”).

The CSSF requires financial market participants (inter alia UCITS management companies and authorized AIFMs – “FMPs”) to participate in this data collection exercise by providing a set of information relating to precontractual product disclosures for each sub-fund managed by them in accordance with the details set out in the User Guide.

The CSSF points out that this reporting is mandatory for SFDR Article 8 Funds, Article 9 Funds as well as Article 6 Funds. The participation of FMPs subject to Article 2(2) or 3(1) of the Law of 12 July 2013 is voluntary.

In addition, the CSSF outlines that the initial reporting by the FMPs is to be submitted to the CSSF no later than 15 June 2023. After the initial report, FMPs continue to be responsible for keeping the information provided up to date. Each time relevant information contained in the SFDR precontractual documents/templates changes, FMPs must update the data reported in the SFDR data collection by submitting subsequent declarations.

The User Guide mentioned above describes all mechanisms for the submission of the report via eDesk or a structured file through S3 (“simple storage service”) protocol.

The CSSF intends to extend the current data collection exercise to collect information contained in the PAI statements and in the periodic disclosure templates.

For further information, please see CSSF communication dated 24 March 2023.