The Financial Data Exchange Templates (FinDatEx) Group published on Monday, March 14th, 2022 two new documents:
1. The official version of European ESG template (EET)
The FinDatEx group launched the final version of the European ESG Template (EET) V1.0 on February 4th, 2022, which was open for feedback until February 25th, 2022. After evaluating and incorporating the feedback, the final version is now available and can be found here.
The implementation of the EET will have two phases in order to cover both regulatory relevant deadlines:
- August 2nd, 2022 – consideration of investor’s sustainable preferences according to MiFID II and IDD
- January 1st, 2023 – SFDR and Taxonomy Regulation-driven reporting obligations
Timeline as explained in the EET Disclaimer:
The version V1 provides Mandatory [M] / Conditional [C] information due to be delivered from 1. June 2022 to distributors and insurers for ESG MiFID/IDD start date as of 1. August 2022
Funds will need to provide pre-contractual and periodic disclosures under SFDR RTS as of 1 January 2023. In consequence, certain information in relation to the SFDR RTS is not considered as Mandatory for the initial version of the EET that is asked to be provided by 1 June 2022. In the interim period (1 June 2022 to 31 December 2022), product manufacturers may determine the minimum share of Taxonomy-aligned/sustainable investments as well as PAI consideration for the respective fund according to their planning for pre-contractual commitments and may indicate the internally determined value in the relevant fields. […]
This procedure is possible in the interim period until the SFDR-compliant pre-contractual and periodic information becomes available. Distributors and insurers as well as other users of the EET should be aware that the information transmitted before 1 January 2023 does not necessarily have to be reflected in the fund documents. In case funds make the relevant commitments before 1 January 2023, the fields shall be populated according to the field description.
2. Updated Version of the European MiFID Template (EMT V4)
The EMT has been updated as a consequence of the introduction of the EET. The EMT V4 will replace the currently co-existing V3 and V3.1 and will be the only version of the EMT going forward. The following changes have been made:
- Update wording of data field 05105
- Deletion of country specific ESG-related data fields of v3.1
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