SFDR Update January - May 2023

May 29, 2023

This update covers the period from the second half of January 2023 until the end of May 2023. Several interesting publications from public authorities regarding the Sustainable Finance Disclosure Regulation EU 2019/2088 (SFDR) have been made during the period. Our view on the main takeaways for Swedish and Norwegian AIFMs is listed below.

Updated editable versions of pre-contractual and periodic reporting templates


The European Supervisory Authorities (ESAs) provided updated versions of the templates set out in the Delegated Regulation EU 2022/1288 of the SFDR (RTS).

 

The following templates exist in editable version in English: pre-contractual templates for article 8 and 9 funds, periodic reporting templates for article 8 and 9 funds, and principle adverse impact statement template.

 

The editable versions are accessible through the ESMA or EIOPA website by clicking here.

 

Permian comment: This was a welcomed publication of editable versions of the latest templates.


The RTS are in force in the EU as of 1 January 2023 but not yet in Norway. We nonetheless recommend that Norwegian AIFMs prepare their disclosures under the SFDR in accordance with the RTS.


Proposed changes to the SFDR RTS


The ESA’s published a consultation paper proposing amendments to the RTS on 12 April 2023. Proposed amendments include a) simplification of pre-contractual and periodic disclosure templates; and b) additional social indicators for the calculation of principle adverse impact.


For further information, please click here.


Permian comment: To be noted. No action necessary by AIFMs at the moment.


Updated Q&A from the European Commission


On 14 April 2023, additional answers on the SFDR were published. Some of the key matters covered were the following:


  • The definition of sustainable investment was clarified as follows: a) a transition plan itself is likely not sufficient to qualify as a sustainable investment (i.e. an activity that has a future aim to meet the 'do no significant harm' (DNSH) criteria is not sufficient); and b) the SFDR does not set out minimum requirements regarding concepts such as contribution, DNSH or good governance. Instead, financial market participants must carry out their own assessment for each investment and disclose their underlying assumptions.


  • The concept to “consider” principle adverse impacts (PAI) was clarified as follows: it means to publish adverse impacts, and to implement procedures to mitigate the harm.


For further information, please click here.


Also, on 17 May 2023, the ESA’s published a document with consolidated Q&A on the SFDR. To access the consolidated version, please click here.


Permian comment:  AIFMs are recommended to ensure that any transition investment under an article 9 fund is supported by more than a transition plan (to qualify as a sustainable investment). Furthermore, AIFMs are recommended to ensure that they have procedures in place to mitigate harmful impacts for investments in funds that consider PAI. There could also be additional information in the Q&A to be considered by AIFMs.


Draft Delegated Act to the Taxonomy Regulation published by the European Commission


On 5 April 2023, the European Commission published, for consultation, a Draft Delegated Act with technical screening criteria for the remaining four environmental objectives under the Taxonomy Regulation. The environmental objectives covered by the draft Delegated Act are the following:

 

  • sustainable use and protection of water and marine resources;
  • transition to a circular economy;
  • pollution, prevention and control; and
  • protection and restoration of biodiversity and ecosystem.


Furthermore, certain additional activities were proposed to be included in the Delegated Act relating to climate adaption and mitigation. Such additional economic activities are, for example, manufacturing activities relating to low carbon transport and electricity equipment and certain transitional activities (waterborne transport and aviation).

 

The Delegated Act is expected to enter into force on 1 January 2024, after which financial market participants may disclose taxonomy alignment based on the activities and environmental objectives included in the Act.


For further information, please click here.


Permian comment: To be noted for taxonomy alignment calculations in SFDR disclosures in 2024.


Greenwashing one of the Swedish Financial Supervisory Authority (SFSA)’s focus areas for 2023


The SFSA published their focus areas for 2023 on 20 January 2023, where greenwashing is one of them.


For further information, please click here. 


Permian comment: The statement stresses the importance of a prudent approach to sustainability-related regulation, with a focus on understanding relevant requirements and how to disclose the work accurately.


Publication from the SFSA on article 6 of the SFDR


On 2 February 2023, the SFSA published a clarification on pre-contractual templates. In its clarification, the SFSA stated that the pre-contractual templates for article 8 and 9 funds in the RTS does not include information in accordance with, for example, article 6.1 of the SFDR. Furthermore, it stated that it is up to the financial market participants to ensure that proper disclosures are included in accordance with the SFDR, Taxonomy Regulation and the RTS.

 

Article 6.1 states that pre-contractual information should include: a) the manner in which sustainability risks are integrated into their investment decisions; and b) the results of the assessment of the likely impacts of the sustainability risks on the returns of the financial products they make available.


For further information, please click here.


Permian comment: AIFMs to ensure that information relating to sustainability risks is included in their pre-contractual information in the main body of an information memorandum (or similar document) since the information is not included in the RTS templates.



Contact:

 

Anna Berntson Petas: anna.berntson@permian.se


Thomas Blomgren: thomas.blomgren@permian.se

Permian’s Commitment to ESG: Supporting AIF Managers on their Sustainability Journey

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.

Practical insights for Norwegian AIFMs from the Swedish implementation of DORA

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.

Empowering Investors with Our Allvue Investor Portal

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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. 

Navigating the SFDR Evolution: SFDR 2.0 and Its Implications for Fund Managers

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.

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.

Permian Advisory, Risk Management and Compliance

February 11, 2025
At Permian, we understand that the complexities of modern investment environments demand robust advisory support, meticulous risk management, and unwavering commitment to compliance. Our specialized services ensure that fund managers and investment companies can navigate these challenges with confidence and focus on achieving their strategic goals.

Permian and Highvern Combine to Create New Leading Fund and Private Capital Services Platform

January 30, 2025
Permian, Telemos Capital (“Telemos”) , and Highvern are pleased to announce the signing of binding agreements to combine Permian and Highvern to create a leading international funds and private capital services provider. Existing shareholders to re-invest alongside both senior management teams. Together the businesses already operate in 7 jurisdictions with close to 300 employees and plan for further accelerated organic growth as a result of the new combination itself, alongside further expansion into new strategically important markets. Telemos, backed by the Jacobs family, will ensure the new group has the financial support to continue investing in its service offerings, people and technology in order to meet clients’ evolving needs. Already leaders in their respective markets, the Permian and Highvern brands are long-established and have built strong reputations for service quality and the strength of their client relationships. These will remain central to the group’s future values and strategy. Philippe Jacobs, Chairman and Founder of Telemos, and Johan Pettersson, Head of Business Services commented “We are excited to be able to bring these two first rate businesses together and are grateful to both management teams for their trust by choosing us as their partner. By leveraging our sector expertise and international network, we look forward to supporting the management teams with their plans to create a next generation, customer-centric, international funds and private capital services provider.” Marianne Normann, CEO at Permian added that “Following Telemos’ investment in Permian last year this announcement is an early demonstration of the benefits of working alongside forwardthinking partners. Together with Highvern, we are excited to expand our reach and serve our clients in new geographical markets. The combined group will be differentiated in the market by its high-quality service offering enabled by technology, allowing us to grow alongside our clients”. “Family capital is the ideal source of growth funding for an ambitious and respected business like ours” said Martin Hall, CEO at Highvern. “We have got to know the Telemos team closely over the last few years and can be confident that we will continue to serve our clients with the same focus on quality while accelerating our fund administration and private capital service lines in this new combination.” Subject to regulatory approvals the transaction is expected to close by mid-2025. Media contacts

Season's Greetings from Permian

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Permian Business Partner Recognized as a DN Gaselle 2024

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We are excited to announce that Permian Business Partner has been named a Gazelle Company for 2024 by Dagens Næringsliv. This recognition is based on meeting several criteria, including achieving profitability and doubling our turnover over the past four years.  Being included on the Gazelle list is an acknowledgment of our growth and the consistent efforts of our team. We are proud of this achievement and deeply appreciate the trust and support of our clients and partners, who have been vital to our progress.

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At Permian, our Fund Administration team works behind the scenes to ensure seamless operations for our clients. By managing the backbone of fund operations, we enable fund managers to focus on what they do best. Our team delivers a comprehensive suite of services, including investor and FSA reporting, liquidity management and forecasting where investor calls and distributions are important tasks, investor onboarding where we offer a fully outsourced KYC solution, handling of subscription forms for underlying investments, and coordinating with external advisors when there are several parties involved. In short, we take care of the details so our clients can stay focused on their priorities.
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