Beyond the label: How SFDR 2.0 could redefine sustainable funds

What is the Sustainable Finance Disclosure Regulation?

The Sustainable Finance Disclosure Regulation (SFDR) was introduced by the EU Commission as a core component of its 2018 Sustainable Finance Action Plan. As a key pillar of the EU Sustainable Finance agenda, SFDR aims to improve transparency, prevent greenwashing and help investors make informed sustainable investment decisions. To do so, the SFDR introduced mandatory disclosure requirements around environmental, social and governance (ESG) metrics at both the entity and the product levels.

An imperfect system

Since taking effect in March 2021, the SFDR has faced implementation challenges and criticism from market participants. In a 2023 consultation, the EU Commission found that 83% of respondents believed the regulation was being used as a product label and marketing tool, rather than solely as a disclosure framework. Respondents highlighted several concerns, including greenwashing risks linked to inconsistent product classifications, unclear definitions, limited ESG data availability and higher compliance costs. Together, these challenges have made implementation more difficult and limited SFDR’s ability to provide transparent, comparable information on sustainable investments.

This has prompted the EU Commission to consider revisions to the framework, culminating in the draft SFDR 2.0 proposal.

Is it the end of Article 8 and 9?

Not quite. Rather than eliminating these categories altogether, the proposal replaces the existing Article 6/8/9 disclosure framework with a revised product classification system that introduces clearer definitions, eligibility criteria and sustainability thresholds.

What might change?

Contribution requirement

• One of the most significant proposed changes is that at least 70% of a fund’s assets would need to satisfy the sustainability criteria of its chosen category, whereas the current SFDR provides managers with greater flexibility to determine the applicable threshold.

Transition (Article 7)

• This entirely new proposed category, Transition, is intended for funds investing in companies that are on a credible pathway towards improved sustainability performance.

ESG Basics (Article 8)

• To qualify under the category of ESG Basics, investments would generally need to satisfy at least one of several sustainability tests such as: outperforming the benchmark on ESG ratings or key sustainability indicators, demonstrating improved sustainability characteristics or meeting minimum sustainability standards. This marks a significant shift from the current framework, replacing the broad flexibility currently afforded to managers with more standardized qualification criteria.

Sustainable (Article 9)

• The Sustainable category remains the highest sustainability classification and is expected to be subject to the most stringent eligibility criteria. Although there is broad support for maintaining this as the highest sustainability category, negotiations continue around how sustainable investments should be defined in practice.

Mandatory exclusion criteria

• Under the current regulation, investing in an ESG or sustainable fund does not necessarily prevent exposure to controversial sectors, such as fossil fuels, tobacco or prohibited weapons. Under the proposed SFDR 2.0 framework, mandatory exclusion criteria would apply across all sustainability categories, with the scope and stringency of exclusions increasing for higher-ambition categories.

These proposed changes would work to ensure that a fund could substantiate its sustainability claim with clearly measurable criteria, assuaging greenwashing risks.

Where do negotiations stand?

The legislative process is progressing rapidly. The EU Council published its negotiating position in June, while the European Parliament is expected to adopt its position shortly. Once both institutions have finalized their positions, trilogue negotiations with the European Commission will begin alignment on the final SFDR 2.0 framework.

Implementation timeline

The trilogue negotiations are expected to begin this autumn. While the timing remains uncertain, the legislative process is likely to extend through 2027, followed by a transition period before the new rules apply. Based on the current timetable, SFDR 2.0 is unlikely to become applicable before 2029, although the exact implementation date will depend on the pace of negotiations and the final transition period.

What does this mean for investors?

While the final rules are still being negotiated, the overall direction is becoming increasingly clear: sustainability claims will need to be supported by more objective and measurable criteria. An analysis by Clarity AI estimates that around 40% of current Article 9 funds would not meet the proposed exclusion rules of the highest sustainability category. 80% of Article 8 funds would experience the same challenge.

For asset managers and investors, these reforms could materially affect how sustainable funds are designed, marketed and compared, making the final outcome particularly relevant for investment strategies with ESG objectives. Funds currently designated as sustainable under Article 8 or 9 may need to be strategically revisited with portfolio or policy adjustments if the intent is to maintain the same designation levels.

At Global Alpha, we are following these developments closely. While SFDR 2.0 remains subject to negotiation, the direction is clear: sustainability claims will increasingly need to be supported by objective, measurable criteria. We will continue to monitor the legislative process and its implications for the sustainable investment landscape as the final framework takes shape.