SFDR PASI Market Study 2025: Where Does the Market Stand?

Two years after the first SFDR PASI statements were published, cleversoft revisits the market to assess how far Financial Market Participants (FMPs) have come in aligning ESG KPI disclosures. Here you can find the whole study.

Dynamics in the ESG Regulatory Landscape

The first SFDR reporting cycle in 2023 marked a major milestone in sustainable finance transparency. However, it also revealed significant inconsistencies in how ESG KPIs were calculated and disclosed. The first market study we carried out in 2023  showed that methodologies varied widely, and comparability across Financial Market Participants (FMPs) was limited.

It became clear that the initial requirements set by the EU Commission had to be revised and in response, the European Supervisory Authorities (ESAs) initiated a series of updates to the SFDR Regulatory Technical Standards (RTS), explained in our blog post on the RTS proposals — resulting in the SFDR 2.0 draft and the 2025 consolidated Q&A — covered in detail in our update on the ESAs’ Q&A.

These updates aim to:

• Improve comparability across disclosures

• Clarify definitions and calculation methodologies

• Align SFDR with the upcoming Corporate Sustainability Reporting Directive (CSRD), which will serve as a key input source for SFDR calculations

cleversoft’s 2025 PASI Market Study: Scope and Method

These trends indicate a stronger move toward alignment in PAI disclosures and a clearer commitment to ESG transparency.

Key Findings

1. Calculation Methodology:

The 2025 study shows that FMPs rely on the ESAs’ Q&A and also on the the SFDR 2.0 draft when calculating KPIs that lack clear definitions in the current RTS. This trend reflects a growng effort to standardise disclosures and improve comparability. The ESAs’. Q&A guidance is increasingly visible in how KPIs are calculated, particularly for GHG emissions and social indicators. As an example PAI 5 in Table 1 (Share of non-renewable energy consumption and production), where most FMPs report a combined KPI output, consistent with the SFDR 2.0 draft.

Another example with a key point of debate concerns the denominator for certain PAI KPIs, where the regulation specifies “current value of all investments” but does not define the term precisely. Based on discussions with our clients and also based on the the study we can clearly identify three distinct interpretations of “current value of all investments”:

• “All investments” – the full scope of the investment/entity portfolio is used, without excluding any investments based on the nature of the respective investment itself. This is the approach advised in SFDR 2.0 draft

• “Covered investments” – the scope of the investment/entity portfolio, that has available reported or estimated ESG Data for the respective PAI covers. For example, consider PAI 4 Table 1 (Exposure to companies active in the fossil fuel sector) calculated with this denominator. That would mean that any investments, which do not have any available ESG data would be excluded from the denominator and a reweighting of the portfolio would be needed to consider that.

• “Status Quo“ – when the calculation for GHG PAIs from Table 1, i.e. PAI 1 (GHG emissions), PAI 2 (Carbon footprint), PAI 3 (GHG intensity of investee companies) and PAI 15 (GHG intensity of investee countries), the full scope of the investment/entity portfolio is used, without excluding any investments based on the nature of the respective investment itself, as defined in the regulation, while all other PAIs are calculated in with the denominator “Covered investments“

• other: where we can observe that there are also provider specific interpretations of the regulation on the market

>> Key Finding is that there is still divergence in denominator choices. More that 50% of reviewed statements stick to what planned in SFDR 2.0 and use the denominator “All investments”, while 20% apply the denominator “Covered investments“. This variation affects the comparability of reported KPIs and highlights the need for further clarification in the final RTS updates.

2. Coverage Improvements

Comparing 2023 and 2025, cleversoft observed minor but continuous improvements in data coverage across all PAI “groups”, including:

• GHG-related PAIs (PAI 1 Table 1, GHG Emissions): Coverage continues to strengthen, moving from around 80% in FY 2022 to over 90% by FY 2024. This reflects a maturing baseline, where greenhouse gas disclosures are increasingly standardised and widely reported.

• Other environmental PAIs (PAI 8 Table 1, Emissions to water): Although still relatively limited, coverage has doubled within two years, increasing from 15% in 2022 to around 30% in 2024. This shows growing attention to broader environmental impacts beyond carbon emissions.

• Social PAIs (PAI 10 Table 1, Violations of UN Global Compact and OECD Guidelines): Data availability improved gradually, climbing from roughly 80% in 2022 to nearly 90% in 2024.

• Sovereign and supranational PAIs (PAI 16 Table 1, Investee countries subject to social violations): Coverage has remained consistently high about 95%, at reflecting either the broad accessibility of this information or the fact that many companies invest primarily in pre-screened countries .

• Real estate PAIs (PAI 17 Table 1, Exposure to fossil fuels through real estate assets): In contrast, disclosure remains marginal, with coverage hovering at only about 3%. This highlights a persistent data gap in real estate–related sustainability indicators.

These improvements suggest that companies are either investing in issuers with better ESG data availability or enhancing their own data sourcing capabilities. The trend points to a maturing ESG data landscape, where transparency and completeness are becoming standard practice.

Despite progress, data gaps remain. Investee company and fund ESG reported data remains in relative low numbers for specific PAIs and FMPs resolve to using estimated data, and social KPIs related to supply chains show limited coverage. These gaps indicate areas where further data integration and standardisation are needed. Current expectations on the Market are that with the finalisation of the Omnibus package and the changes it will introduce to the CSRD, such data deficiencies will be closed.

3. General Conclusions

   1. Methodology on “Optional” PAI Choice: Most FMPs have not changed their selection of “optional” PAIs from Table 2 and Table 3 and continue to report on the same indicators chosen in the first reporting period for reference year 2023.

      • The most frequently reported Table 2 indicator is PAI 4 (Investments in companies without carbon emission reduction initiatives).

      • The most frequently reported Table 3 indicator is PAI 9 (Lack of a human rights policy).

      Some FMPs have expanded their reporting to cover more than one optional PAI from each table.

   2. PASI RTS Alignment – the latest available RTS template is followed, however some FMPs add additional pages for marketing purposes or general structure of the file (banner as first page, additional information). Most FMPs are reporting their PASIs in a landscape format due to the increased columns for historical comparisons (as per RTS and the ESA Q&A’s, up to 5 reference years are to be included in the PASI Statement, currently 2 reference years are required as first reporting period is reference year 2022)

   3. PASI Importance – in the current calendar year, there is an increased amount of available PASIs online and they are more easily accessible on the respective FMP websites. This can be considered as an increased importance to the PASI reporting due to more companies being in scope of the regulation and/or a bigger importance of the ESG topic across the market and general geopolitical landscape.

   4. PASI Comparison between FMPs – Compared to 2023, 2025 PASI’s are more comparable, however different calculation methodologies do have an impact on an exact comparison possibility. Current expectations on the Market are that with the finalization of the Omnibus package and the changes it will introduce to the CSRD, companies will align more on their calculation methodology based on an updated Regulation and comparisons will be possible across the entire market.

These trends indicate a stronger move toward alignment in PAI disclosures and a clearer commitment to ESG transparency.

What This Means for Your Company

The SFDR framework is maturing and ESG KPI comparability is no longer just a regulatory ambition, it is slowly becoming a practical reality. However, SFDR 2.0 finalisation is subject to the Omnibus discussions, and final publications will be key milestones to watch. These will determine how the RTS evolves and what actions FMPs must take to quickly adapt.

cleversoft’s service is designed to help clients navigate this evolving landscape with confidence:

• Support for all SFDR Disclosures incl. EET collection and generation

• Flexible calculation methodologies tailored to your data sources and reporting needs

• Ongoing updates aligned with RTS developments and ESAs guidance

Whether you’re preparing for CSRD disclosures or refining your SFDR reporting, cleversoft provides the tools and expertise to stay ahead of regulatory developments.

Visit our SFDR Service to learn more and see how we can support your ESG reporting journey