Report from the NFSA of Compliance with the SFDR

August 12, 2025

On 25 June, the Norwegian Financial Supervisory Authority (the “NFSA”) published a report on Norwegian asset manager’s compliance with the SFDR.

The report presents the main outcomes from a survey conducted by the NFSA of investment firms and selected fund managers and managers of UCIT funds and AIFMs in 2024 and 2025.


Our overall take on the report is that it includes recommendations to entities in scope of the SFDR that are new to the market. This means that many entities are presumably not in full compliance with the recommendations in the report. Some of the recommendations and our comments are as follows:


  • Article 6 – product level disclosure in pre-contractual documents: The report states that this disclosure should at a minimum include information about which sustainability risks have been identified as the most relevant for each product, and what measures have been taken to mitigate these risks.


Permian comment: To prepare for this disclosure, it is recommended to involve the AIFM’s risk manager. Permian holds a separate risk session when preparing this disclosure where all relevant risks are identified, mitigating activities are included and likely impact on returns of the fund are assessed.  We recommend taking this into account for future pre-contractual documents and the 4-2 form (No. 4-2 skjema).


  • Article 5 - Information on how remuneration policies are consistent with the integration of sustainability risks. According to this article, AIFM’s must disclose how their remuneration systems consider sustainability risks. The report states that the assessment of the NFSA is that this provision is mandatory for all financial market participants, including for registered AIFM’s.


Permian comment: This is a clarification which has not been obvious to the market. Several registered AIFM’s may not have disclosed this information since it is not mandatory for such AIFM’s to have a remuneration policy. We recommend that registered AIFM’s update their website disclosures in accordance with the report.


  • Article 4 - PAI statements at entity level. The NFSA found that many AIFMs fail to comply with SFDR Article 4 requirements on Principal Adverse Impact (PAI) disclosures. Common issues include missing or inadequate PAI statements, vague methodologies, unclear use of external data, and poor justification for indicator selection. Few firms explain how they track progress or adapt when no improvement occurs. Some firms wrongly claim that PAI is irrelevant or cite insufficient data and lack of client demand. These are justifications NFSA does not accept. Overall, there is a clear gap between regulatory expectations and current market practices.


Permian comment: In October 2024, ESMA published a valuable report on PAI disclosures that we find particularly helpful when preparing compliant statements. We recommend that all managers, whether required to report on PAIs or doing so voluntarily, review the report, as it provides useful guidance for improving the quality and clarity of their disclosures. Link to the report can be found here.


  • Article 7 - Transparency of adverse sustainability impacts at financial product level. This is a comply-or-explain provision where AIFM’s can opt to consider “PAI” at fund level or explain why PAI data is not taken into account. In the report, the NFSA points out that limited access to data alone is not sufficient justification for not considering PAI, and further notes that the SFDR allow for reasonable assumptions to be made and that taking PAI into account therefore, can be achieved even if detailed data is not available.


Permian comment: This is an already known position from the NFSA and should be considered for future pre-contractual disclosures and in the 4-2 form.


  • Article 8 and 9 – Sustainable investments. As regards sustainable investments, the NFSA repeats a statement from an ESMA document that such products must take into account mandatory PAI indicators in SFDR level 2, table 1 in annex I, as well as relevant optional PAI indicators from tables 2 and 3, in the DNSH assessment.


Permian comment: To be noted as a reminder.


  • Article 10 – Product-level website disclosures. The report clarifies that the NFSA expects all financial market participants to disclose all article 8 and 9 product-level disclosures on their public website and not exclusively on websites that require login.


Permian comment: Although most Norwegian AIFMs already follow this, it is a clarification that might not be obvious if the AIF is a closed fund since all applicable investors would in such case have access to the disclosures on the investor portal.


  • Article 11 – Periodic reporting. The report clarifies the NFSA’s expectations regarding the annual report for article 8 and 9 funds. The report states that the quality of the reviewed reports varied significantly, particularly when explaining how environmental or social characteristics were achieved. Common weaknesses included unclear presentation of external data and poor comparability with benchmarks. In some cases, disclosures were not easily accessible, undermining regulatory requirements.

 

Permian comment: We note that some managers fail to define clear, measurable KPIs in their pre-contractual disclosures to track the achievement of environmental or social characteristics. This lack of upfront clarity often results in weak periodic reporting, as noted by NFSA. We recommend that managers establish well-defined KPIs supported by reliable data sources from the outset. Periodic reports should clearly demonstrate progress toward sustainability goals, with transparent explanations of data sources and methodologies (especially when benchmark comparisons are used). The aim is to make sustainability reporting both credible and easy for investors to understand.

 

Please click here for a link to the NFSA report.

Key Contacts

May 8, 2026
Permian and Highvern are delighted to welcome Polly Lister as Head of Legal and Company Secretary, based in the UK, further strengthening the group’s legal and governance capability. Polly brings extensive experience from senior legal roles within the international financial services sector, advising private wealth centres across the Crown Dependencies and EMEA.
April 27, 2026
We are delighted to welcome Jason Burgoyne, who joins Highvern & Permian today as Group Chief Operating Officer and member of our Group Executive Committee. Based in the UK, Jason will be working with colleagues across our business, bringing deep client and operational expertise as we continue to enhance our processes and capabilities to support consistent service excellence, as well as invest in our technology, data management and AI. His appointment reflects our ongoing commitment to scaling our capabilities and delivering the highest standards for our clients across the Group.
April 14, 2026
Highvern and Permian (the “Group”), backed by Jacobs Capital, are pleased to announce the appointment of Anne Storie as Head of Funds Americas, based in the Cayman Islands. Anne will join the business on 20 April 2026, becoming a member of the Group’s Executive Committee and joining the Cayman-regulated boards, subject to regulatory approval. This appointment marks another important step in the Group’s strategy to expand into key markets and strengthen its position as a leading international provider of fund services and private capital solutions. It builds on the Group’s recently announced partnership with PANDOO, a leading Luxembourg-based provider of fund services and reflects the Group’s ongoing investment in talent and technology to support long-term sustainable growth. Anne’s appointment enhances the Group’s fund services offering for clients in the Americas, providing access to broad asset class expertise across the Group’s multi-jurisdictional platform. She will work closely with colleagues across the business, bringing together highly skilled specialist teams to meet clients’ increasingly international needs while delivering consistent service excellence. Anne brings more than 20 years’ experience in the global funds sector, with a strong track record of building and scaling fund services businesses across the Americas. Most recently she was Global Head of Strategic Alliances and Country Head of Cayman Islands at Apex Group. Prior to this Anne held leadership roles at Ashland Park Advisory and was CEO Americas and Group Board Member at Waystone. She has a strong industry presence and currently serves as Chair of the Government Trade and Business Licensing Board, Cayman Islands. Caroline Connellan, Group CEO at Highvern & Permian, said: “I’m delighted to welcome Anne to Highvern & Permian. Her deep industry expertise, strong client focus, and leadership experience will be instrumental as we continue to invest in our Cayman offering, expand our reach into the Americas, and deliver greater choice to clients across asset classes and jurisdictions. Following our recently announced partnership with PANDOO, Anne’s appointment is a further step in positioning the Group to better address the increasingly complex needs of clients while continuing to deliver the service standards they expect.” Commenting on her appointment Anne Storie said: “I am excited to be joining Highvern & Permian at such an important point in its growth journey, as the Group continues expand its presence into key strategic markets. There is a clear opportunity to build on the strong platform in Cayman and further enhance the Group’s offering for clients in the Americas. I look forward to working with colleagues across the business to strengthen our capabilities and deliver high-quality service and client-focused solutions.”
March 4, 2026
London, Luxembourg 04 MARCH 2026 PANDOO, Highvern and Permian (the “Group”) are pleased to announce the signing of binding agreements to combine the businesses, with the continued backing from Jacobs Capital. This partnership represents a significant milestone in the Group’s strategy to expand into key strategic markets and further consolidates its position as a leading international provider of fund services and private capital solutions, following Jacobs Capital’s investment to combine Highvern and Permian in 2025. PANDOO’s senior management will reinvest alongside Jacobs Capital and existing Highvern and Permian shareholders. Founded in 2009 by Charles Meyer, PANDOO is a leading independent Luxembourg-based provider of administration and management services for investment vehicles, offering a fully integrated, end-to-end platform for alternative investment structures. It brings proven Luxembourg expertise, an established and growing client base, and a reputation for high-quality client service. The newly combined Group will operate in nine jurisdictions with over 400 employees. This provides clients with greater choice and immediate access to Luxembourg, Europe’s leading alternative investment fund market, complementing the Group’s existing footprint including the Cayman Islands, Guernsey, Ireland, Jersey, Norway, South Africa, Sweden and the UK, and supporting accelerated organic growth. Clients will also have access to broader asset class expertise, including PANDOO’s experience in high-growth sectors such as real estate, real asset structures and private debt, alongside private equity and venture capital. Together, the businesses share a strong client-centric approach and a commitment to service quality, underpinned by ongoing investment in people and technology. The combined Group increases scale and international reach, bringing together highly skilled and specialist teams with closely aligned cultures and shared values. This positions the Group to better address increasingly complex client needs, deliver consistent service excellence, and support long-term sustainable growth. Subject to regulatory approvals, the transaction is expected to close in the second half of 2026. Martine Grün, John Wantz, Sven Rein, Partners at PANDOO, said: "We are excited to join forces with Highvern and Permian. Jacobs Capital is the right partner for us – they understand our culture, invest for the long term and empower entrepreneurial teams. Together, we share a strong focus on client service, agility and ownership, which will enable seamless collaboration from day one. Our Luxembourg expertise will thrive within this broader international platform. We thank our dedicated team and valued clients for their trust and support as we embark on this exciting journey together." Caroline Connellan, Group CEO at Highvern & Permian, said: “We are delighted to welcome PANDOO to the Group. Our partnership brings together highly skilled people and complementary businesses with closely aligned cultures and shared values. As a Group, we have an exciting opportunity to offer clients greater choice across asset classes and jurisdictions, while continuing to deliver the service standards they expect. We are very much looking forward to working with the PANDOO team.” Johan Pettersson, Head of Business Services at Jacobs Capital, said:  “We see the combination of PANDOO with Highvern and Permian as an important step towards building a next-generation, truly international, differentiated platform for fund services and private capital solutions. We are grateful for the opportunity and trust given to us to support PANDOO in its future strategy and will continue to invest in its people, technology and service excellence.” Media contact 
February 25, 2026
For many fund managers, ESG data collection started as an afterthought rather than a structured operational process. How ESG data is collected is often a clear indicator of how seriously a fund approaches ESG. And under the Sustainable Finance Disclosure Regulation (SFDR), it is no longer a nice-to-have. In this article, Permian’s ESG Director Agata Bremer outlines the typical stages of ESG data maturity, the practical challenges funds face at each step, and what a more sustainable set-up looks like. "For many in the alternative investment industry, ESG reporting started as an afterthought: a spreadsheet here, an email there, a template dropped into SharePoint the week before an LP request landed. That approach worked when ESG was a nice-to-have. Under SFDR, it no longer does. The margin for error is much smaller, and manual processes break down quickly", says Agata. The four stages of ESG data maturity Most fund managers fall somewhere along a spectrum from fully manual to fully integrated, according to Agata. Understanding where you are positioned matters, because the risks and costs of staying put differ significantly at each stage. Stage 1: Spreadsheets and email Excel trackers, Google Sheets, and ESG data collected via email from portfolio companies. This is where most funds start. The setup is simple and flexible, but manual entry increases errors, audit trails are weak, and tracing data back to source quickly becomes painful. Stage 2: Standardised templates in cloud storage Structured questionnaires stored in SharePoint or OneDrive improve consistency and version control. Internal coordination improves, but the process remains manual. Each reporting cycle requires consolidation, follow-ups, and significant hands-on effort, which limits scalability. Stage 3: ESG software platforms Dedicated ESG tools centralise data collection, automate aggregation, and create an audit trail. For many mid-size PE and VC funds with SFDR Article 8 obligations, this is a logical next step. The limitation is that platforms only work well if roles, timing, and data ownership are already clearly defined. Stage 4: Integrated ESG data infrastructure ESG data collection is embedded into the broader fund administration and portfolio monitoring setup. Reporting is largely automated, and regulatory defensibility is stronger. This stage requires more upfront investment but delivers the highest level of control and efficiency. This is where we see large PE firms and multi-fund managers heading, but it requires mature internal processes and meaningful investment before the benefits land. Where problems usually arise According to Agata, ESG reporting issues are rarely caused by technology. “The real problems are almost always about process and ownership,” she says. Common failure points include collecting data only once a year under time pressure, unclear responsibility for chasing and validating data, and expanding reporting scope without a clear data structure to support it. A realistic way to improve Funds don’t need fully integrated infrastructure immediately. What matters is sequencing. “Start by defining exactly which ESG metrics are required and why. Then standardise how those metrics are collected, even if that still happens in spreadsheets. Only once the data flow is stable does it make sense to introduce software or broader system integration,” Agata explains. “The tool matters less than the discipline behind it,” she concludes. “A simple, well-run process will always outperform a sophisticated system that’s poorly implemented.” Need support? At Permian, we support alternative investment fund managers in building ESG data processes that stand up to SFDR requirements and scale with portfolio complexity. Get in touch to discuss how your current ESG data setup can be strengthened and scaled.
February 16, 2026
As regulatory pressure increases and non-financial risks become critical, fund managers face higher expectations on governance and resilience. Erik Elkan, Risk Manager at Permian in Sweden, discusses the changing role of risk and how Permian in Sweden supports managers through this shift. Erik, you work with risk management for Permian in Sweden. Can you tell us a bit more about your area? At Permian, we work with Swedish Alternative Investment Fund Managers (AIFMs) that have outsourced their risk management function to us. Our specialist team covers all risk requirements under laws such as AIFMD, AIFMR, and relevant local regulation, acting as designated risk managers. We work across different asset classes and fund structures, providing both strategic guidance and regular oversight. What are the main risk-related challenges fund managers face today? Fund managers operate in an environment where risks are more diverse and fast-moving than ever. Cybersecurity and third-party dependencies remain critical, while ESG and climate-related expectations are rapidly intensifying. At the same time, new frameworks such as the Digital Operational Resilience Act (DORA) and upcoming AI Act are reshaping operational risk requirements. How do your risk management services support clients? We help fund managers stay ahead by continuously updating risk frameworks, integrating risk awareness and operational resilience into their systems, and ensuring that both governance and reporting withstand regulatory scrutiny. Permian offers a complete, ready-to-implement risk management function that integrates directly into a fund manager’s governance framework. We follow an annual risk management plan, complemented by ad-hoc assessments as needed, to support regulatory compliance and operational resilience. Our services include risk policies and procedures reviews, regulatory monitoring, risk assessments for funds and manager, and stress testing, as well as regular board reporting. Our approach combines tailored models across key risk areas with structured reporting to senior management, making risk management efficient, transparent, and aligned with supervisory expectations. Why do fund managers choose Permian as their risk partner? Our clients partner with Permian for access to an established framework, specialised tools, and a multidisciplinary risk team that can scale with their business. This allows fund managers to focus on investment performance while maintaining strong regulatory control. Looking ahead, how do you see the risk landscape evolving? Technology such as AI, data analytics, and automation will increasingly shape how risks are identified and managed. Non-financial risks and geopolitical uncertainty affecting market risk are moving to the forefront alongside tighter regulatory expectations. In this environment, fund managers need a trusted, long-term risk partner who understands the full scope of risk management. At Permian, we are preparing for this shift by developing scalable, technology-supported risk frameworks grounded in regulatory expertise and backed by professionals with deep insight into both regulation and business reality. With a fully outsourced function, we act as a trusted professional with a clear understanding of the evolving risk landscape. Read more about our Risk Management Services here.
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Fam Dang, new Team Leader for Accounting in Norway shares reflections on why accounting is about more than “just” numbers.
By Adam Brodin January 12, 2026
Felix Edgren has joined Permian as Country Head Sweden and Head of Fund Administration & Accounting, effective 12 January. His appointment forms part of the combined Permian and Highvern Group . Felix brings extensive experience from asset servicing, capital markets and fund administration. He joins Permian from Apex Group, where he held several senior leadership roles, including Country Head Sweden and Regional Head Corporate Solutions Nordics. Prior to this, he held senior positions at Nordic Trustee, TMF Group and Intertrust Group. Felix has experience working across the Nordics and Luxembourg. Johanna Bjenne, Interim Country Head Sweden and Head of Fund Administration & Accounting, says: “We are very happy to welcome Felix to the team. His operational and strategic experience, deep understanding of the Swedish market, and client-focused leadership make him well equipped to support our continued growth in Sweden while further strengthening the quality and delivery of our fund services.” Commenting on his new role, Felix says: “Permian holds a leading position in the Nordics, and I’m excited to be joining Permian and Highvern as we continue to expand in capacity and scale. I look forward to contributing to the team and continuing delivering best-in-class services to our clients in Sweden.” Johanna Bjenne will transition back to her role as Head of Fund Operations, Onshore.
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Permian and Highvern, together with Jacobs Capital, announce the appointment of Caroline Connellan as Group Chief Executive Officer.
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