CSSF on Application of Sustainable Financial Disclosure Regulation
A statement from CSSF clarifies which entities that are established in Luxembourg and are subject to the CSSF supervision are considered as financial market participants and financial advisers for the purpose of the Sustainable Finance Disclosure Regulation in EU (SFDR or Regulation 2019/2088). The statement also highlights that EC confirmed the application dates of SFDR. As stated in the EC letter dated October 20, 2020, all application dates are being maintained as laid down by the SFDR with effect from 2021; the financial market participants and financial advisers subject to SFDR will need to comply with its high level and principle-based requirements from March 10, 2021, even though the regulatory technical standards, which were initially expected to be available by December 30, 2020, will become applicable at a later stage.
SFDR lays down harmonized rules for financial market participants and financial advisers on transparency with regard to the integration of sustainability risks, the consideration of adverse sustainability impact in their processes, and the provision of sustainability‐related information with respect to financial products. As clarified in the CSSF statement, financial market participants include alternative investment fund managers (AIFMs), Undertakings for Collective Investment in Transferable Securities (UCITS) management companies, managers of a qualifying venture capital fund or a qualifying social entrepreneurship fund, credit institutions and investment firms that provide portfolio management, and institutions for occupational retirement provision (IORPs). Additionally, financial advisers include credit institutions, investment firms, AIFMs, and UCITS management companies that provide investment advice. EC believes that, even without the full regulatory technical standards, there are no impediments to financial market participants and financial advisers complying with the Level 1 requirements laid down in the SFDR.
Related Links
- Statement (in French)
- EC Letter (PDF)
- SFDR
Keywords: Europe, Luxembourg, Banking, Insurance, Securities, ESG Regulation 2019/2088, SFDR, Disclosures, Climate Change Risk, Sustainable Finance, ESAs, EC, CSSF
Featured Experts

Michael Denton, PhD, PE
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
Previous Article
ECB Updates Documentation on SHS Reporting by BanksNext Article
ESMA Updates Q&A on Benchmarks Regulation in EURelated Articles
APRA Publishes Results of Climate Risk Self-Assessment Survey
The Australian Prudential Regulation Authority (APRA) has published the findings of its latest climate risk self-assessment survey conducted across the banking, insurance, and superannuation industries.
ACPR Publishes Updates Related to CRD IV and Covered Bonds
The French Prudential Supervisory Authority (ACPR) published a notice related to the methods for calculating and publishing prudential ratios under the Capital Requirements Directive (CRD IV) and the minimum requirement for own funds and eligible liabilities (MREL).
EIOPA Publishes Guidance on Climate Change Scenarios in ORSA
The European Insurance and Occupational Pension Authority (EIOPA) published the risk dashboard based on Solvency II data and the final version of the application guidance on climate change materiality assessments and climate change scenarios in the Own Risk and Solvency Assessment (ORSA).
EBA and ECB Respond to Proposals on Sustainability Disclosures
The European Banking Authority (EBA) and the European Central Bank (ECB) published their responses to the consultations of the International Sustainability Standards Board (ISSB) and the European Financial Reporting Advisory Group (EFRAG) on sustainability-related disclosure standards.
BIS Report Notes Existing Gaps in Climate Risk Data at Central Banks
A Consultative Group on Risk Management (CGRM) at the Bank for International Settlements (BIS) published a report that examines incorporation of climate risks into the international reserve management framework.
EBA Publishes Multiple Regulatory Updates for Regulated Entities
The European Banking Authority (EBA) published the final guidelines on liquidity requirements exemption for investment firms, updated version of its 5.2 filing rules document for supervisory reporting, and Single Rulebook Question and Answer (Q&A) updates in July 2022.
EIOPA Issues SII Taxonomy and Guide on Sustainability Preferences
The European Insurance and Occupational Pensions Authority (EIOPA) published Version 2.8.0 of the Solvency II data point model (DPM) and XBRL taxonomy.
EESC Opines on Proposals on CRR and European Single Access Point
The European Union published, in the Official Journal of the European Union, an opinion from the European Economic and Social Committee (EESC); the opinion is on the proposal for a regulation to amend the Capital Requirements Regulation (CRR).
HM Treasury Publishes Multiple Regulatory Updates in July 2022
HM Treasury published a draft statutory instrument titled “The Financial Services (Miscellaneous Amendments) (EU Exit) Regulations 2022,” along with the related explanatory memorandum and impact assessment.
APRA Consults on Prudential Standard for Operational Risk
The Australian Prudential Regulation Authority (APRA) is seeking comments, until October 21, 2022, on the introduction of CPS 230, which is the new cross-industry prudential standard on operational risk management.