SFDR update: What it means for asset managers – August 2025

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).

On 4 August 2025, the ESAs published a new Q&A on the SFDR and its regulatory technical standards. These clarifications have been long awaited and make the framework more practical – and easier for asset managers to navigate. 


What does the update say about Principal Adverse Impact (PAI) indicators? 

Two things stand out. First, water usage and recycling (PAI 6) have finally been defined more clearly. The ESAs now refer to the European Sustainability Reporting Standards (ESRS), which break the indicator into three measures – water consumption, water intensity relative to revenue, and the percentage of water recycled or reused. For asset managers, this means more structured data collection from investee companies. 


Second, for real estate, the ESAs confirmed that energy consumption per square meter should be calculated based on useful floor area – the part of a building that is actually in use. This aligns with the EU Taxonomy and makes reporting more consistent and comparable. 


Why does this matter for managers? 

For anyone with exposure to real estate or industrial assets, these clarifications reduce guesswork. They bring consistency across portfolios and make benchmarking easier. 


What about disclosure templates – what’s new there? 

The ESAs addressed two areas. On top investments in periodic reports, there isn’t one mandatory calculation method. Managers should follow sector rules such as AIFMD. Many already use quarterly Net Asset Value (NAV) snapshots to calculate average exposures – which also captures investments sold during the period. If a portfolio remains unchanged, year-end figures are enough. 


On minimum percentages of sustainable investments, Article 8 and 9 funds can now state separate minimum shares for environmental and social investments. These don’t have to add up neatly to the overall minimum commitment, as long as managers explain the remainder. 


Can you give an example? 

A fund could commit to 100% sustainable investments, with at least 20% environmental and 10% social. The remaining 70% can be allocated flexibly – but the 20% and 10% minimums still need to be met. This provides managers with flexibility while giving investors clarity. 


What’s your overall take? 

For our clients – especially those with real estate and production assets – this guidance is very welcome. Even with this Q&A, managers often need to cross-check several regulations to see the full picture. But these clarifications make the SFDR framework more practical and reduce uncertainty. 


More information

Read the full ESAs publication [pdf] via this link.


Key contacts at Permian 

Jannike Ludvigsson

Senior ESG Advisor

‭+46708916105

jannike.ludvigsson@permian.se

Agata Bremer

Director ESG

+46 760 06 44 02

agata.bremer@permian.se

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Anna Berntson Petas

Head of Legal and Compliance - Onshore

+46 723 30 53 31

anna.berntson@permian.se

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