The Disclosure Regulation : ESG Deadlines for

Asset Managers
June 30, 2021 January 1, 2023
March 10, 2021 Q3 / Q4 2021 January 1, 2022 June 30, 2022 Dec. 30, 2022
PAI Comply Big Funds / Second
First Application Date Integration Period First Taxonomy Alignment PAI Statement PAI Disclosure
Managers Taxonomy Alignment

Sustainable Risks Policy Structural/organizational

changes aiming at
integration of sustainability
Manager Level

Policy on principal adverse First PAI statement

impact (PAI) (“comply or Integrate sustainability and (quantitative only)
explain”) MIFID suitability into assumed that next one will
investment processes be each 30 June annually

Updated remuneration Mandatory disclosure of

policies (integration of PAI policy if 500+
sustainability risks) employees

Additional disclosures on Optional PAI disclosure at Additional disclosures on

specific characteristics Additional disclosures on fund level (how financial Taxonomy alignment for
(sustainability risk policy, Taxonomy alignment for products comply) Environmental Taxonomy
impact on sustainability Climate Taxonomy Funds Funds
risks on returns)
Product Level

Statement of non- SFDR Level 1 periodic

compliance for managers reports for all products to
not implementing PAI include additional
policy sustainability

Additional disclosures for

products with sustainable
investment objective or
promoting sustainability