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

December 10, 2025
Permian and Highvern, together with Jacobs Capital, announce the appointment of Caroline Connellan as Group Chief Executive Officer.
Permian's new office at Jakobsbergsgatan 17.
December 9, 2025
To support Permian’s continued growth, its expanding Nordic client base, and its long-term commitment to providing best-in-class fund services, the company has relocated from Vasagatan 36 to new offices at Jakobsbergsgatan 17 in the Mood District. The new premises at Jakobsbergsgatan offer a modern and flexible workplace that accommodates Permian’s nearly 70 employees in Sweden. The office features expanded meeting facilities, improved collaboration areas, and increased workstation capacity to support the company’s continuously growing team and cross-border operations. “Alongside our mission to deliver high-quality services to our clients, our new office gives us room to scale and welcomes focused work as well as innovative and meaningful conversations with partners, clients, and colleagues. A huge thank you to everyone who has been part of this journey so far,” says Johanna Bjenne , Country Head, Sweden. The new office is fully operational. Updated contact details are available on Permian's website under "Contact".
November 19, 2025
As the global fund landscape evolves, cross-jurisdiction collaboration is becoming essential. For the newly combined Highvern and Permian group, that momentum begins with Ireland and the Nordics, where teams are already working together to strengthen onshore fund services and deliver seamless, client-focused solutions across eight jurisdictions: Ireland, Sweden, Norway, Jersey, Guernsey, the UK, South Africa, and the Cayman Islands. Country Heads Emma Keane (Ireland), Johanna Bjenne (Sweden), and Susanne Berge-Hansen (Norway) share insights on how the unified group – now over 300 colleagues with $45bn in assets under administration – is creating value for clients through integrated expertise and a connected, multi-jurisdictional platform. Strength across borders Emma Keane (EK): What makes clients look outside Sweden or Norway when setting up structures in other jurisdictions? Johanna Bjenne (JB): For Swedish managers, it’s a mix of access to capital, tax considerations and investor comfort. Many institutional investors are used to Ireland or Luxembourg structures, so being able to offer that option through the same group helps facilitate a seamless solution. It’s not just a tax discussion anymore - it’s about investor confidence, reputation, and long-term visibility. Susanne Berge Hansen (SBH): It’s similar in Norway. Managers want stability and regulatory consistency. By working closely with our Irish colleagues, we can compare and combine options to find the best fit for each client. The fact that this can now happen within the same organisation makes a big difference - it’s faster, simpler, and built on shared trust. EK: Clients increasingly expect that continuity. Having Ireland, Sweden, and Norway as well as our offshore offering in Jersey, Guernsey and Cayman under one group allows us to offer local presence and international reach in a single connected network of expertise. Enhancing expertise & innovation EK: We’ve already seen teams working more closely together since the integration. How is that translating into client opportunities right now? SBH: It’s already changing how we think. For example, Highvern’s Irish team has deep experience in areas like debt and private credit, while our Nordic clients are exploring those same asset classes. We can now bring that knowledge straight into client discussions, rather than learning from scratch. JB: Yes and on our side, we’re supporting more clients who want digital access and data visibility. As part of a larger group with shared technology development, we’re now able to offer those tools faster. It’s a real, practical benefit that’s happening today. EK: And it’s two-way. We’re learning from the Nordic teams’ approach to client engagement -that mix of precision and partnership. You can already feel that shared energy across our teams. Having recently been successful on a pitch, referred from our Permian colleagues, for a Swedish manager looking to launch an Irish ICAV for their royalties’ fund, demonstrating not only the further jurisdictional reach but also the depth of expertise between both teams, the client was able to feel the benefit from the outset of the relationship. JB: At Permian, our values - caring, precise, and challenging - are really lived day to day. Joining a bigger group always raises questions about culture. How do you see that playing out? SBH: The key is that our values align. Highvern’s focus on quality, integrity, and client service mirrors what we’ve built at Permian. That means collaboration feels natural, you could see how quickly people connected - same mindset, just different accents! EK: That’s so true. The offsite really confirmed how strong that alignment is. Everyone’s ambitious but grounded, and that balance is what will help us scale without losing who we are. Impact for clients EK: Looking at the market today, what are the biggest topics your clients are focused on? JB: There’s a lot of attention on AIFMD II and ESG reporting. Clients want administrators who can not only comply but also help interpret what’s coming. Having a bigger, connected group means we can share insights and act faster when new regulation lands. SBH: Governance and data transparency are also high on the agenda. Clients expect partners who can combine strong regulatory understanding with modern digital delivery - and that’s exactly where we’re investing together as a group. EK: We’ve become one group with a shared purpose, and clients are already seeing the benefits - broader expertise, deeper resources, and a network that connects Ireland, the Nordics, and beyond. Not only does this extend to our Highvern and Permian colleagues, but also our strong network of intermediary relationships in each jurisdiction to help meet our clients needs. JB: It’s an exciting time. We’re not talking about a distant future - the collaboration is happening now, and it’s energising our teams and clients alike. You can feel the momentum. With a shared purpose and connected teams, we are already delivering enhanced onshore fund expertise, deeper resources, and seamless solutions for our clients – today and into the future.
November 6, 2025
As ESG regulation becomes a central part of the investment ecosystem, fund administrators take on a broader role. Agata Bremer, ESG Director at Permian, reflects on how this development builds on the existing strengths of fund administration — why administrators are uniquely positioned to deliver ESG services, and what it takes to adapt.
October 27, 2025
Meet Eleona Skreosen, Fund Administrator at Permian. With a background in Sustainable Finance and experience across hedge funds and health tech, she shares what drew her to Permian — and what makes her work here exciting
September 24, 2025
Jannike Ludvigsson, Senior ESG Advisor at Permian, answers key questions about the European Supervisory Authorities’ (ESAs) latest update on Sustainable Finance Disclosure Regulation (SFDR).
August 18, 2025
Several interesting publications from public authorities regarding the Sustainable Finance Disclosure Regulation EU 2019/2088 (SFDR) and linked sustainability regulations have been made during June and July 2025. Our main takeaways for Swedish and Norwegian AIFMs are listed below.
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.
July 4, 2025
Dear clients, business partners and colleagues, As the long, sunny days of summer arrive, we extend our warmest wishes for a refreshing and enjoyable holiday season. In the past six months we have strengthened our team with talented new colleagues and sustained strong growth across our core services. We also joined forces with Highvern , broadening and deepening the support we provide and we are now present across seven jurisdictions. We are now using Allvue as our main fund administration platform. With Allvue in place, we have a highly efficient and secure IT solution in place, handling everything from accounting to all elements of fund administration, as well as allowing integrations to other systems through open APIs. Allvue also offers a professional Investor Portal that enables seamless investor reporting, performance tracking and enhances investor interaction through interactive dashboards. With the solid backbone in place, Allvue will strengthen the overall quality of our service, fully aligned with our commitment to delivering “Everything Correct” . We have also reinforced our ESG commitment by developing tailored ESG services specifically designed to support and offload AIF managers. These milestones reflect our dedication to tech innovation, operational excellence, our ESG ambitions, and above all your success. We are already energized by the progress we have made so far this year and are eager to pick up where we left off once the break is over. Until then, thank you for your trust and collaboration. From all of us at Permian, have a wonderful, restful and sun-filled summer holiday!
June 10, 2025
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.
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