Regulatory Agenda -- top priorities for 2021

Sustainability-related disclosure regulation (SFDR)

4 February
The European Supervisory Authorities (ESA) publish the final draft of the Regulatory Technical Standards (RTS) on the PAI indicators (Principal Adverse Impact Indicators) to be disclosed by financial market participants (such as insurance companies or product manufacturers) with more than 500 employees. Mandatory and optional PAI indicators are defined for companies, states and supranational organisations as well as real estate. The RTS also include details on pre-contractual and periodic information to be disclosed on financial products that pursue ESG strategies or impact investing (Articles 8 and 9 Products under SFDR).

12 February
FinDaTex publishes an interim version of the European MiFID Template (EMT 3.1).

10 March
SFDR Level 1: Financial market participants and financial advisors must disclose how they deal with sustainability risks on their website and in pre-contractual documents on financial products. For financial products under Articles 8 and 9 of the SFDR, additional information on sustainability aspects in the investment strategy (such as implementation of sustainable objectives) must also be disclosed.

30 June
Major financial market participants and product manufacturers with more than 500 employees must disclose their policies for considering PAI indicators. While smaller companies can avoid this, they must then disclose why they do so.

Q3-Q4
Expected applicable date for MiFID II, UCITS, AIFMD, IDD and Solvency II Amendments.

31 December
SFDR Level 2: The environmental or social characteristics for financial products under Articles 8 and 9 of the regulation must be disclosed in periodic reports, in pre-contractual documents and on the website. The reference period for quantitative disclosure on PAI disclosures begins.

30 Juni 2023
First reports with complete quantitative PAI data should be available by mid-2023 for the reference period. Start of the second reference period.

Taxonomy

31 December
Companies in scope of NFRD must disclose to what extent they perform EU Taxonomy eligible activities for climate change mitigation and adaption. Financial products must disclose in periodic reports how they meet environmental and social objectives and to what extent they invest in EU Taxonomy eligible activities for climate change mitigation and adaption. The first company reports and investor disclosures using the EU taxonomy are due in early 2022 covering fiscal year 2021.

28 June
Implementation deadline for the majority of CRR II provisions. The reports are due for the first time as of June 30, 2021, based on the new CRR II and the revised reporting forms.

Q3
European Commission expected to publish legislative proposals amending Solvency II.

31 December
UCITS regulated by PRIIPs.