SFDR Update June - August 2023
August 28, 2023
This update covers the period from June until mid-August 2023. The main update is that the EU Commission published a Sustainable Finance Package on 13 June 2023. Our view on the main takeaways for Swedish and Norwegian AIFMs is listed below.
Implementation timeline for sustainable finance regulations published by ESMA
On 3 August 2023, ESMA published an updated implementation timeline for sustainable finance related regulations. The timeline can be accessed here.
Permian comment: ESMA publishes updated implementation timelines on regular basis. It is an excellent document to obtain an overview of the sustainability related legislations and their entry into force.
Sustainable Finance Package
The Sustainable Finance Package published on 13 June 2023 covers the following five main areas:
- Proposal on a new regulation for ESG rating providers: this regulation will apply to service providers of ESG ratings and includes a definition of ESG ratings. It does not apply to service providers of ESG raw data. Its entry into force is subject to the EU legislative process.
- Taxonomy delegated acts: the EU Commission adopted the delegated acts that were mentioned in our SFDR Update January – May 2023. Expected entry into force is 1 January 2024.
- Transition finance: this recommendation provides information on how companies can use tools from the EU for transition finance. An example provided in the recommendation is that companies can use the Taxonomy by reporting Taxonomy-aligned capital expenditure (i.e. since this would generally provide for a higher alignment in a transition context than reporting Taxonomy-aligned revenue). In addition, the recommendation includes information that could be included in a transition plan.
- Clarification on the link between taxonomy-alignment and sustainable investment under the SFDR: according to this notice, investments in taxonomy aligned environmentally sustainable economic activities can be automatically qualified as “sustainable investment” under the SFDR (provided that the taxonomy-alignment relates to the entire company and not only a part of the company’s economic activities).
- Staff working document on the Taxonomy: this document includes a summary of the Taxonomy, tools to be used as well as links to other documents related to the Taxonomy.
For further information, please click here.
Permian comment: The package does not include additional reporting obligations on the Manager. For further comments, see below.
- ESG ratings: to be followed-up with any ESG rating provider used by the Manager closer to the regulation’s entry into force. (Please note that the definition of ESG rating providers is not fully clear to us.)
- Taxonomy delegated acts: to be considered for Taxonomy assessments as of 2024.
- Transition finance: to be considered in connection with e.g. preparing a transition plan and for asset managers with a transition finance investment mandate.
- Clarification on the link between taxonomy-alignment and sustainable investment under the SFDR: the practical implication of this clarification is that any investment that has been assessed as taxonomy-aligned can also be assumed qualify as a sustainable investment under the SFDR. This should mean that if you disclose that you have taxonomy-aligned investments, then those investments could also be disclosed as sustainable investments in the periodic reporting. Please note however, that if you use this new presumption, then you should first read the clarification since there are some exceptions (such as when a portfolio company’s economic activities have not all been assessed as taxonomy aligned).
- Staff working document on the Taxonomy: this document could be read as a summary of the Taxonomy and includes some useful links.
Amendment to the Norwegian Regulation under the Sustainable Finance Act
On 13 June 2023, the EEA Committee decided to incorporate Regulation (EU) 2022/1214 into Annex IX of the EEA Agreement. This regulation amends Regulation (EU) 2021/2139, which encompassed a broad range of energy-related activities but lacked technical screening criteria for the fossil gas and nuclear energy sectors, and Regulation (EU) 2021/2178, which fell short in achieving full transparency for these economic activities. With the Amendment Regulation, the fossil gas and nuclear energy activities are now recognized as environmentally sustainable activities with respect to EU’s 6 environmental objectives. The Amendment Regulation has been implemented into Norwegian law in Section 2 of the regulation under the Sustainable Finance Act and came into effect 14 June 2023.
For further information, please click here.
Permian comment: Relevant entities should review how the amendments are applicable to them.
Contacts
Anna Berntson Petas: anna.berntson@permian.se
Thomas Blomgren: thomas.blomgren@permian.se
Felicity Guttormsen: felicity.guttormsen@permian.no
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.
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.
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.
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.
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, 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
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.
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.
