SFDR update: What it means for asset managers - June and July 2025

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.

ESMA promotes clarity in sustainability-related communications

On 1 July 2025, ESMA published a thematic note on sustainability-related claims used in non-regulatory communications. The note focuses on the use of labels and rewards. The main message in the note is that non-regulatory communications such as marketing materials and voluntary reporting should be fair, clear and not misleading. The note includes examples of good practices and poor practices as well as do’s and don’t’s.


Please click here for a link to ESMA’s publication.


Permian comment: Since the note highlights the importance of avoiding greenwashing, AIFM’s are best advised to ensure that all information to investors, potential investors and others is aligned with the regulatory sustainability reporting. For this to happen, AIFM’s compliance team could work together with the marketing team. These are a few topics that could be considered:


  • Information that is missing: This is often the case for AIFMs when publishing data. The note recommends including information on limitations of information and data and metrics used.
  • Information kept up-to-date: Since information should be kept up to date, it is good practice to include in the annual compliance wheel to check, not only regulatory disclosures, but also (material) non-regulatory communication on at least a yearly basis.
  • Claims about industry initiatives: Avoid referencing an initiative once the AIFM has left it.


Final report from ESMA on the integration of sustainability risks and disclosures 

On 30 June 2025, ESMA published a summary report of a thematic review conducted by supervisory authorities in the EEA during 2023-2024. The aim of the review was to investigate whether authorised managers, being UCITS and AIFMs, complied with the SFDR and organizational requirements in the AIFMD and UCITS framework on sustainability risks.

 

Please click here for a link to ESMA’s publication.


Some of the main takeaways from the report:


  • Avoid making generic or excessive claims with regarding sustainability characteristics, and ensure marketing materials, pre‑contractual documents, website disclosures, and periodic disclosures are consistent.

 

Permian comment: It is important that all sustainability-related disclosures provided by the AIFMs are consistent and clear on how the characteristics are measured and fulfilled. To achieve this, AIFMs compliance and marketing teams could work together. On top of this, it is good practice to always review all periodic reports against the commitments made in the pre-contractual and website disclosures.

 

  • Ensure that sustainability risks are integrated in the decision-making procedures and in the AIFM’s organization. According to the report, on a structural level sustainability risks in the portfolio are often dealt with by the investment team and risk manager. The conclusion in the report is that managers, generally, monitor sustainability risks on a continuous basis.


Permian comment: In general, AIFM’s updated their policies in 2022/2023 by including the concept of sustainability risks in several areas such as in the conflict-of-interest policy. This was a result of an amendment in the Delegated Regulation (EU) No 231/2013 (“AIFMR”) which entered into force 1 August 2022. For a revisit of the regulation amending the AIFMR, please find it here.



Permian comment: Managers may consider documenting training programs and FTE allocations for ESG tasks to demonstrate commitment and preparedness in case of regulatory scrutiny.


  • Ensure clear definitions and robust procedures to identify and manage greenwashing-related conflict of interest.

 

Permian comment: For AIFM’s in general, it may be difficult to point out a materialized greenwashing risk under the conflict-of-interest policy. Instead, we assess that greenwashing is avoided by setting a proper structure in the investment process to ensure that sustainability risks are considered ahead of an investment. As a good example, a separate one-pager could be included in the investment memorandum covering sustainability risks as well as other relevant regulatory SFDR matters depending on type of fund.


  • The report includes good and bad examples in several areas. One such area is the disclosure of PAI data at entity level and product level.

 

Permian comment: These sections are a recommended read to assess good and bad examples or find information about various methodologies used by other asset managers.

 

Report from the NFSA of asset managers’ compliance with the SFDR

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


Please find our separate update on the report here.

Key Contacts

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 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.
May 27, 2025
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.
March 27, 2025
In today’s fast-paced financial landscape, providing your investors with a seamless, secure, and professional experience is more important than ever. That’s why we’re proud to offer our Allvue Investor Portal—a dynamic solution designed to enhance communication, streamline operations, and empower investors with the tools they need to stay informed. 
March 14, 2025
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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