The Central Bank of Ireland has published an Industry Communication clarifying the filing procedure for UCITS and AIFs to comply with upcoming pre-contractual documentation update requirements. The Sustainable Finance Disclosures Regulation ("SFDR") requires financial market participants and financial advisers, which includes UCITS management companies and Alternative Investment Fund Managers ("AIFMs"), to make pre-contractual and ongoing disclosures to end investors with regard to the integration of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social characteristics and sustainable investment. To facilitate orderly implementation of these requirements, the Central Bank has established a streamlined filing process for pre-contractual document updates based on the SFDR Level 2 requirements, under which both UCITS management companies and AIFMs will be required to certify compliance with the requirements via an attestation.
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.
