The Central Bank of Ireland ("Central Bank") has confirmed it will establish a fast-track filing process for the pre-contractual document updates relating to the Sustainable Finance Disclosure Regulation Regulatory Technical Standards ("SFDR Level 2").
The deadline for filing with the Central Bank using the fast-track process will be 1 December 2022.
As part of the fast-track filing process:
- An attestation from the UCITS manager / AIFM will be required confirming that the changes related to SFDR only;
- The cover letter submitted to the Central Bank must identify and provide a rationale for any of the changes that are being made to align with SFDR and recent related EU level clarifications; and
- Pre-contractual disclosures should be sent in as standalone pdfs separate from the prospectus (for technical reasons).
Both UCITS and AIFs will have to follow the fast-track process and adhere to the deadline.
The Central Bank has indicated that it will undertake a review / spot-check of a sample of submissions received.
Interestingly, the Central Bank has indicated that fund re-classifications will be allowed under the fast-track process. In such circumstances, the UCITS manager / AIFM should ensure to explain the rationale for the change of classification in its cover letter.
Further details in respect of the fast-track process are expected to be made publicly available in due course and we will provide a further update once available.
How can the Maples Group help?
The Maples Group is working with numerous managers on the SFDR Level 2 requirements. If you would like further information, please liaise with your usual Maples Group contact or visit our dedicated ESG Hub.
unknownx500
