The Central Bank has confirmed that there will be a fast-track filing process for prospectus updates on foot of the Sustainable Finance Disclosures Regulation ("SFDR") and the deadline for such filings will be 1 December 2022.
The fast-track facility will capture broader SFDR-related updates but an attestation will be required that the changes relate to SFDR only. Fund re-classifications will be allowed under the fast-track process where the rationale for the change is detailed in the cover letter. There is ongoing engagement with the Central Bank with regard to certain formatting challenges and other points of clarification and we will keep you updated as further details on the process emerge. We are also awaiting the outcome of the European Supervisory Authorities' (ESAs) further queries to the European Commission of 9 September 2022 relating to the interpretation of SFDR which can be reviewed here.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.