Understanding the Relationship Between CSRD, EU Taxonomy, and SFDR: A Comprehensive Guide

Sustainable Finance and ESG Reporting in the European Union

Sustainable finance is pivotal in steering the EU toward its climate and environmental objectives by channeling investments into eco-friendly projects and initiatives. Complementary to this, sustainability reporting is crucial for enhancing transparency in the areas of environmental, social, economic, and governance factors.

Such reporting helps organisations identify risks and opportunities linked to sustainability, enabling them to build a resilient and future-proof business model. It also allows for meaningful engagement with stakeholders, fortifying trust through a clear commitment to sustainable conduct. From the EU's perspective, this dual approach not only empowers investors with the information needed for conscientious decision-making but also establishes accountability measures for corporations, thereby discouraging greenwashing.

Overall, sustainable finance and reporting serve as key instruments in the EU for promoting responsible business practices, incentivizing sustainability, and fostering innovative solutions to environmental challenges. They achieve this by ensuring transparency through reliable and comparable ESG data, providing a common language for stakeholders to make informed decisions.

The EU sustainable finance framework includes the EU Taxonomy, the Corporate Sustainability Reporting Directive (CSRD), and the Sustainable Finance Disclosure Regulation (SFDR). These three regulations are closely interrelated and work together to support directing investments towards Taxonomy-aligned activities, by enabling investors to identify these activities. In this article, we will dive deeper into each of these frameworks and their relationships:

• What is SFDR?
• What is CSRD?
• EU Taxonomy: Definition and Significance
• Relationship between SFDR, CSRD, and EU Taxonomy
• Implications for Financial Institutions and Corporations
• Practical Application: an Investment Bank under the SFDR
• The EU Taxonomy, CSRD, and SFDR as Pivotal Triad of Regulations
• Greenomy to Help you in your ESG Reporting
  

What is SFDR?

The Sustainable Finance Disclosure Regulation (SFDR) is a European Union regulation designed to elevate transparency in the realm of sustainable investments. Specifically, it mandates that Financial Market Participants (FMPs) and Financial Advisors (FAs) disclose information pertaining to environmental, social, and governance (ESG) activities. These disclosures are required at both the entity level and the product level.

As of January 2023, stakeholders are additionally obliged to adhere to the SFDR Regulatory Technical Standards (RTS), which offer more detailed guidelines for compliance.

The primary purpose of SFDR is twofold: Firstly, it seeks to channel capital into more sustainable investment avenues by providing investors with transparent, standardised information. Secondly, it aims to curb greenwashing—misrepresenting products as more sustainable than they actually are—thereby ensuring that investors are not misled by false or exaggerated claims.

In the context of SFDR, FAs are organisations or entities that offer advice on investment or insurance-based investment products. This category includes entities operating within the EU as well as those based outside the EU that market or intend to market their products to EU clientele.

On the other hand, FMPs are organisations or entities that manufacture and sell financial products or offer asset management services. Like FAs, FMPs can be either EU-based or situated outside the EU, as long as they market or plan to market their offerings to clients within the EU.

You want to learn more about the SFDR? Learn all you need to know in our free comprehensive e-book The Essentials of SFDR.

Key Provisions and Requirements of the SFDR

The SFDR outlines specific obligations for FAs and FMPs to enhance transparency in sustainable investing. Here are the key provisions and requirements:

Classification of Funds

SFDR categorizes investment funds into three types based on their focus on environmental objectives:

• Dark Green Funds (Article 9): These funds have sustainable investment as their primary objective.
• Light Green Funds (Article 8): These funds promote environmental and social characteristics but may not have sustainability as their central goal.
• Grey Funds (Article 6): These funds neither prioritize nor promote environmental or social characteristics.

What is CSRD?

The Corporate Sustainability Reporting Directive (CSRD) is the European Union's most recent legislative framework, mandated to oversee sustainability reporting and officially supplanting its predecessor, the Non-Financial Reporting Directive (NFRD), on January 5, 2023.

CSRD has been designed to both reinforce and expand upon the existing regulations, aiming to bring more coherence and uniformity to the manner in which companies disclose their ESG impacts. This extends not only to the activities of the companies themselves but also implicates their entire value chains.

The main objectives of the CSRD are:

• Standardisation: Standardising ESG disclosures, thereby reducing inconsistency and information gaps to make it easier for stakeholders, including investors and regulators, to evaluate and compare the sustainability performance of different companies.
• Transparency: By mandating comprehensive disclosures, the CSRD aims to increase transparency around corporate ESG activities, enabling better-informed decision-making for investors, consumers, and other stakeholders.
• Alignment with Other Regulations: CSRD is not an isolated piece of legislation. It aligns closely with other EU legislative initiatives, such as the EU Taxonomy and the SFDR, creating a more streamlined and efficient framework for ESG reporting.
  

Learn more in our ebook The Essentials of CSRD.

The Role of ESRS in CSRD Reporting

The CSRD also introduces a noteworthy component: the European Sustainability Reporting Standards (ESRS). The ESRS aims to provide specific guidelines and standards for ESG reporting under the CSRD, ensuring a common methodology and comparability across companies and sectors. In this way, the ESRS serve as the operational backbone of the CSRD, facilitating its broader objectives of standardisation and transparency.

The Relationship between NFRD and CSRD

The CSRD represents a significant departure from its predecessor, the NFRD, aiming to enhance transparency and accountability in sustainability reporting. It extends coverage from 11,700 companies under the NFRD to around 50,000 in the EU, starting phased implementation in January 2024.

Two key innovations are the Double Materiality perspective and the introduction of the European Sustainability Reporting Standards (ESRS). Double Materiality requires companies to disclose how environmental and social factors impact their business and how their operations affect society and the environment, leading to a more comprehensive assessment of sustainability. On the other hand, the ESRS, with detailed and obligatory criteria, bolster data reliability, transparency, and comparability.

In summary, the CSRD sets higher standards for comprehensive, verifiable, and accessible ESG reporting, improving corporate accountability for social and environmental impacts.

The CSRD Complements the SFDR

The CSRD and the SFDR are two complementary regulations that aim to improve transparency and accountability in ESG matters. The CSRD requires large companies to report on their sustainability performance against the EU Taxonomy, while the SFDR requires financial market participants to disclose how their products align with the EU Taxonomy.

The CSRD is relevant for the SFDR because it provides part of the information to be disclosed for the SFDR report. In particular, the CSRD requires companies to disclose their greenhouse gas emissions, water usage, and waste production. This information can be used by financial market participants to assess the ESG risks and opportunities of a company's investments.

The CSRD and SFDR together form a synergistic framework to promote sustainable finance. By requiring companies to disclose their ESG performance and financial market participants to disclose how their products align with ESG factors, these regulations help to ensure that investors have the information they need to make informed decisions.

EU Taxonomy: Definition and Significance

The EU Taxonomy acts as a pivotal classification system for demarcating environmentally sustainable economic activities. By setting robust assessment criteria, it standardises the concept of sustainability across diverse sectors and industries, creating a universally understood language for what qualifies as sustainable.

This framework facilitates multiple objectives: it guides companies and financial institutions in making informed green investment decisions while providing insights into associated financial risks; enables comparative analyses based on quantifiable sustainability metrics; integrates Environmental, Social, and Governance (ESG) factors into broader business strategies; and helps organisations set, achieve, and communicate clear, measurable sustainability goals.

In doing so, it not only fosters informed decision-making but also serves as a countermeasure against 'greenwashing’, where companies falsely claim to be more eco-friendly than they are. Overall, the EU Taxonomy serves as a foundational framework for elevating environmental sustainability as a core consideration in economic activities.

Relationship between SFDR, CSRD, and EU Taxonomy

The EU sustainable finance framework includes the EU Taxonomy, the Corporate Sustainability Reporting Directive (CSRD), and the Sustainable Finance Disclosure Regulation (SFDR).
These three regulations are closely interrelated and work together to support directing investments toward Taxonomy-aligned activities, by enabling investors to identify these activities:

• The EU Taxonomy provides a classification system for sustainable economic activities that is applied within the CSRD and SFDR.
• The CSRD is relevant for the SFDR, as it provides part of the information to be disclosed for the SFDR report.
• Companies affected by the SFDR, in turn, need the EU Taxonomy metrics from the CSRD report of their investment objects to fulfill their reporting obligations.
  

How Adherence to SFDR and CSRD Aligns with EU Taxonomy Requirements

Adherence to SFDR and CSRD aligns with EU Taxonomy requirements as the EU Taxonomy provides a classification system for sustainable economic activities that is applied within the CSRD and SFDR. The CSRD ties into Article 8 of the EU Taxonomy Regulation by requiring companies to report various key performance indicators that are aligned with the EU Taxonomy. The publication of the EU Taxonomy metrics is part of the reporting obligation of companies covered by the CSRD, and companies affected by the SFDR need the EU Taxonomy metrics from their CSRD report.

Therefore, the three regulations are closely interrelated and overlap in terms of content, and they are tools to support directing investments towards Taxonomy-aligned activities, by enabling investors to identify these.

Implications for Financial Institutions and Corporations

SFDR, CSRD, and EU Taxonomy have significant impacts on reporting and disclosure for businesses:

Potential Challenges for Companies in Compliance

• Compliance with these regulations can be challenging for companies, as they may need to collect and report new data, and the reporting requirements may be complex and time-consuming.
• Companies may also face increased pressure from investors to publish sufficient sustainability information in accordance with the CSRD and the EU Taxonomy.
• Companies may need to invest in new systems and processes to ensure compliance with these regulations.

Potential Benefits for Companies in Compliance

• Compliance with these regulations can provide companies with reliable and comparable data, a common language, and informed decisions.
• Companies can use these regulations as a strategic opportunity for transformation, as they can help identify material sustainability topics for stakeholders, include targets and progress, and report in line with the SFDR and the EU Taxonomy Regulation.
• Compliance with these regulations can also help direct investments toward Taxonomy-aligned activities, enabling investors to identify these activities.

Practical Application: an Investment Bank under the SFDR

Consider an investment firm operating within the EU and subject to the reporting requirements of the SFDR. This firm is committed to aligning its investment practices with sustainability goals, embarking on a process that commences with the acquisition of sustainability information from the companies in which it has invested. This information is essential and falls under the CSRD, as well as adheres to the structured classification system provided by the EU Taxonomy.

For our investment firm, complying with SFDR requires not only transparency and disclosure on their part but also reliance on the EU Taxonomy metrics extracted from the CSRD reports of their invested companies. These metrics are instrumental in fulfilling their reporting obligations under SFDR, ensuring that their investments align with the EU's stringent sustainability standards. This cooperative endeavor among the investment firm, CSRD, and the EU Taxonomy not only enhances transparency and accountability within their investment portfolio but also contributes tangibly to environmental goals, showcasing the harmonious synergy between SFDR, CSRD, and the EU Taxonomy in advancing sustainability within the financial sector.

The EU Taxonomy, CSRD, and SFDR as Pivotal Triad of Regulations

The EU Taxonomy, CSRD, and SFDR form a pivotal triad of regulations designed to streamline and fortify sustainable investing practices. Together, they construct a coherent and efficient framework aimed at empowering investors to make more informed and responsible choices and creating a more transparent and accountable corporate environment.

The EU Taxonomy serves as the foundation for sustainable activities, with CSRD and SFDR building on this through aligned disclosure requirements. CSRD focuses on comprehensive company reporting, while SFDR ensures transparency in financial markets, both using Taxonomy metrics. This interconnected framework simplifies compliance and promotes sustainable investment, making it a strategic asset for companies and investors alike. In sum:

• The EU Taxonomy defines economic activities that can be considered environmentally sustainable.
• The CSRD requires companies to report on their sustainability performance against the EU Taxonomy.
• The SFDR requires financial market participants to disclose how their products align with the EU Taxonomy.

These regulations are still in the early stages of implementation, but they have the potential to transform the way that sustainable finance is done. By providing a clear framework for measuring and reporting on sustainability, they can help investors make more informed decisions and companies improve their environmental performance.

Greenomy to Help you in your ESG Reporting

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