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Update – July 20, 2021: Looking for the latest updates to the Sustainable Finance Disclosure Regulation (SFDR) for your ESG reports? Look no further. At cleversoft, we help you — and our customers — stay on top of the latest regulatory updates, as they happen.


Let’s talk how we can help your business.


Connect to a new world of efficiency by utilising cleversoft’s business solutions.

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Let’s talk how we can help your business.


Connect to a new world of efficiency by utilising cleversoft’s business solutions.

Get in touch

An Update on Sustainable Finance Disclosure Regulation (SFDR) and cleversoft ESG Services

Pre-Contractual ESG Disclosures Level II

Update – July 20, 2021:  Looking for the latest updates to the Sustainable Finance Disclosure Regulation (SFDR) for your ESG reports?  Look no further.  At cleversoft, we help you — and our customers — stay on top of the latest regulatory updates, as they happen.

As a member of the FinDatEx working group, we are actively involved in developments related to EET (European ESG Format). Having this intricate level of involvement grants us deeper insights into European market activities which, in turn, helps us paint a clearer picture for you, each time there is a new update.  In the case of the latest SFDR updates, the first piece of information you should know is that pre-contractual and periodic disclosures should be produced as PDFs, by asset managers, in their corporate design.  Afterwards, the PDFs can be handed out by insurers.

For liability reasons, we welcome this approach, especially for our insurers, even if it deviates from the original plan. With the cleversoft Compliance Commitment, we are committed to providing customers with regular updates to the standard Level I document, provided that new regulatory and legally binding changes are published by the responsible supervisor, and adjustments are necessary. In the future, we will offer the collection and distribution of these documents (pre-contractual and periodic disclosures) as a service.

As of today, neither the final Regulatory Technical Standards (RTS) defining the formats of the respective documents nor the EET have been adopted, so the discussion is still ongoing. Additionally, the European Commission sent a letter (on July 8, 2021) to the Council and the European Parliament, stating that they plan to postpone the application date for the Regulatory Technical Standards (RTS) under the Sustainable Finance Disclosure Regulation 2019/2088 by six months, namely from January 1, 2022, to July 1, 2022. Accordingly, we will keep you informed about further developments and consequences.

As an added benefit for cleversoft customers, we will successively exchange today’s Level I documents with the asset manager documents as part of the ESG4insurnace service, so no further IT effort is incurred.

Further ESG modules

In the last few months, we’ve developed our document creation service for the PASI report, according to §4 of the SFDR regulation. This includes the creation of the periodic reports for the cover pool, if the insurer defines the cover pool as an article 8 or 9 product.

Parallel to this, we’re also working in an “IDD-ESG” working group with the GDV and other insurance companies to enable the simplest possible implementation of the ESG IDD requirements for our customers.

To learn more about how we support unit-linked insurance companies with ESG, contact Lisa Waldherr.

Schedule of cleversoft ESG Services:

01.03.2022 – 30.06.2022 – Contacting the asset managers for the delivery of the Pre-contractual Level II documents based on the EET.
01.07.2022 – Issuance of pre-contractual disclosures according to Level II of the SFDR for Art. 8 and 9 products.
Expected October 2022 – IDD ESG requirements.
In 2022 – The first periodic reports according to the Disclosure Regulation are expected to be published by asset managers
30.06.2023 – First PASI reports for 2022 (excluding Scope 3 carbon emissions to be disclosed starting 06/30/2024).

Sessions are available in English and German for banking, insurance, and asset management.

Thursday, September 16th
SFDR for Insurance:  9:00am CEST (German)
SFDR for Insurance:  10:15am CEST (English)

Thursday, September 23rd
SFDR for Banking:  9:00am CEST (German)
SFDR for Banking:  10:15am CEST (English)

Thursday, September 30th
SFDR for Asset Management:  9:00am CEST (German)
SFDR for Asset Management:  10:15am CEST (English)