SFDR Periodic Reporting in 2025: Considerations for Swedish and Norwegian AIFs
February 14, 2025
This post contains some key information for the periodic reporting under the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (the “SFDR”). The periodic report is a mandatory report for all article 8 and article 9 funds under the SFDR.
Background
An SFDR periodic report shall be made available for all alternative investment funds (“AIF” or “fund”) that are considered article 8 or article 9 funds under the SFDR. It should be published six months after the end of the financial year of the AIF.
The purpose of the SFDR periodic report is to disclose to investors the progress made on the sustainability characteristics/objectives set out in the pre-contractual disclosures of the same AIF.
This post aims to highlight some practical observations made from previous year’s SFDR reports and list some key points for consideration when drafting this year’s SFDR periodic report.
Key points for consideration
Start preparing for the SFDR periodic report in time
- The preparation of the contents of the SFDR periodic report is directly related to commitments in the pre-contractual disclosures and you must be able to report on the stated commitments. Permian has noted that many underestimate the time it takes to obtain underlying data from the portfolio companies and to analyze and aggregate the data before including it in the SFDR periodic report.
Timing of the report
- In Sweden, the auditors usually request that the SFDR periodic report is either included in the statutory accounts (Sw. årsredovisning) or that it is at least finalized no later than the statutory accounts if instead included in an investor report.
- In Norway, to date, it is not required to include the SFDR periodic report in the statutory accounts (which includes the report from the board of directors). The SFDR periodic report should be finalized no later than six months after the end of the accounting year and could be included in an investor report.
Using the template provided in the RTS
- The Commission Delegated Regulation (EU) 2022/1288 (the “RTS”) sets out the templates for the periodic reports in Annex IV and Annex V, for article 8 and 9 funds respectively. It is only permissible to make minor adjustments of these templates, namely: a) to adapt size and font type of characters and colours (article 2.1 of the RTS), and b) to remove sections that are not applicable to the fund in question, if those sections are accompanied by a red text instruction that explicitly limits the scope of application of the section, as clarified in a consolidated Q&A from the three European supervisory authorities EBA, ESMA, and EIOPA (together “ESA”).
- The SFDR templates are available in English on the ESMA website which can be accessed here.
Alignment with pre-contractual disclosures
- The SFDR periodic report is based on the commitments and statements of the pre-contractual disclosures. We strongly encourage managers to make a side-by-side comparison with the pre-contractual- and website disclosures of the fund when preparing the SFDR periodic report, to ensure alignment and coherence between the disclosures and the SFDR periodic report.
Publish the SFDR periodic report on the manager’s/fund’s website. (We also note that some managers publish the SFDR periodic report alongside other fund specific SFDR disclosures on an investor portal.)
Consider regulatory updates since the SFDR periodic report published in 2024
- Please find a list below of more material updates.
Relevant regulatory updates during 2024
During 2024, there have been two important regulatory events impacting the SFDR periodic report:
Q&A on the SFDR
- On 25 July 2024, the ESAs published an updated consolidated Q&A on the SFDR (see link to the consolidated Q&A above), which has been analyzed in detail in a previous news update on our end: SFDR Update for Asset Managers - August 2024
CSSF sanction of fund manager for non-compliance with the SFDR
- On 15 October 2024, the Luxembourg FSA (the “CSSF”) fined an AIF manager for non-compliance with the SFDR. The AIF manager manages an AIF consisting of five separate sub-funds and the fine regarded all five sub-funds. For sub-fund number one, the investments made were misaligned with the ESG scores in the pre-contractual disclosures. For sub-funds two through to five, the CSSF noted that the means put in place by the AIF manager to measure its targets for sustainable development goals were inadequate. The AIF manager was subsequently fined EUR 56 500 for non-compliance across the five sub-funds.
- Permian Comment: The sanction shows the importance of ensuring that a fund reports in accordance with its pre-contractual disclosures. Managers must be able to measure to what extent investment objectives are met and report accordingly. For fund-of-funds underlying assets will be more difficult to control. Managers of fund-of-funds should therefore be careful in presenting its sustainability strategy. Finally, it is interesting to note that sanctions for ESG are beginning to materialize.
Key Contacts
Anna Berntson Petas
Head of Legal and Compliance
+46 723 30 53 31
anna.berntson@permian.se
Axel Høvo Daasvand
COO
+47 911 82 765
ahd@permian.no
Jake Ljungberg
Jr Legal Counsel & AML
+46 761 25 84 65
jake.ljungberg@permian.se
At Permian, we believe that sustainability is more than just a regulatory requirement—it’s an essential part of creating long-term value to investors in the private equity markets. As the ESG landscape continues to evolve at a rapid pace, we’re committed to being a trusted partner for AIF managers navigating this complex terrain. The introduction of regulations such as the Sustainable Finance Disclosure Regulation (SFDR) and the EU Taxonomy has brought both challenges and opportunities for fund managers. Understanding the requirements, aligning with investor expectations, and integrating ESG into operations can feel overwhelming and time consuming. That’s why we’re developing tailored ESG services specifically designed to support and offload AIF managers in their journey toward compliance and sustainable growth. Services that are a natural extension of Permian’s long-standing values: Precise, Challenging, and Caring. “At the heart of our commitment is a focus on finding and building the best, most efficient solutions to support the ESG journey of AIF managers. We understand the complexities fund managers face and are dedicated to making the process as easy and seamless as possible,” says Agata Bremer, Head of ESG at Permian. By leveraging innovative and effective tools, streamlined processes, and expert guidance, we aim to reduce the efforts and any burden of compliance and create clarity in an otherwise complex regulatory landscape. Our approach is hands-on, operative and collaborative. Through ongoing dialogues with clients, including workshops and one-on-one support, we aim to uncover pain points and identify practical solutions. Whether it’s simplifying ESG reporting, aligning investment strategies with sustainability goals, or addressing regulatory obligations, our goal is to provide actionable guidance that truly makes a difference. We’re excited about the opportunities ahead and look forward to helping AIF managers turn handling of sustainability from a challenge into a competitive advantage. Together, we can create lasting impact for businesses, investors, and the environment.
The Digital Operational Resilience Act (Regulation (EU) 2022/2554), commonly known as DORA, aims to address the growing reliance on Information and Communication Technology (ICT) in the financial sector and mitigating its associated risks. As of January 17 2025, DORA is applicable in the EU. Throughout autumn of 2024, Swedish Alternative Investment Fund Managers (“AIFMs”) subject to DORA have made substantial progress in implementing and ensuring compliance with the regulation. Effective DORA implementations have started with the formation of a cross-functional project group and conducting a gap analysis to align existing frameworks with DORA requirements. Key components include establishing an ICT risk management framework, implementing incident response procedures, and managing ICT third-party risks through updated contracts and a comprehensive register of information. Compliance systems have enabled Swedish AIFMs to optimize data handling and maintain technical accuracy. Norway’s legislative proposal for DORA was adopted on 20 May 2025, and the Dora Act expected to enter into force between summer of 2025 and January 2026. The first mandatory reports are anticipated in early 2026. Given DORA’s extensive requirements, Norwegian AIFMs should initiate preparations now to ensure timely compliance. At Permian, we have actively advised and consulted Swedish AIFMs throughout this process, gaining valuable insights into the practical steps for successful DORA compliance. In the full article, we outline the key considerations and actions Norwegian AIFMs should take as they prepare for the upcoming implementation of DORA in Norway. For access to the full article, please click here. Update: The DORA Act in Norway will enter into force on July 1, 2025.
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The Sustainable Finance Disclosure Regulation (SFDR) has been a cornerstone of the EU’s sustainable finance framework, but its implementation has revealed challenges, particularly around product classification and transparency. In response, on 17 December 2024, the EU Platform on Sustainable Finance released a briefing note outlining a proposed new categorization system to provide clearer guidance and improve investor understanding. This proposal is currently under review and has yet to become final legislation. However, with the SFDR revision scheduled for Q4 2025, fund managers must stay proactive in understanding and preparing for the new classification system. This article explores the proposed changes, insights from the ESAs’ joint opinion on SFDR, and what these developments mean for fund managers, investors, and the broader financial ecosystem.
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