SFDR periodic reporting: the Annex IV and V templates

Every Article 8 and Article 9 fund owes investors a yearly sustainability report card. It is a mandatory annex to the annual report, and it is where the fund's own figures meet the binding minimums in its prospectus. The CSSF ran exactly that comparison in its review under the ESMA common supervisory action (CSSF feedback report on the ESMA common supervisory action, section 3.3.2).

The rules sit in four places. The Level 1 text is the Sustainable Finance Disclosure Regulation, Regulation (EU) 2019/2088. The templates sit in the SFDR RTS, the technical standards in Delegated Regulation (EU) 2022/1288. Delegated Regulation 2023/363 amended them for fossil gas and nuclear. The green-share maths comes from Articles 5 and 6 of the Taxonomy Regulation. The ESAs fill the gaps in their consolidated SFDR Q&A (JC 2023 18, 4 November 2025). It also carries the Commission's interpretation answers.

This page is the how-to. It covers which template you file, what goes in each section, how the taxonomy percentage works and what moves when a fund is relabelled. It does not repeat the calendar. For the dates themselves, including the 30 June PAI statement and the annual-report deadlines the product disclosures ride on, see SFDR and Taxonomy disclosure deadlines.

SFDR product disclosure runs in three layers that must tell the same story. They are what the fund promises before investment, what it keeps on its website, and what it reports after the year. A fourth disclosure, the principal adverse impacts (PAI) statement, sits at the level of the manager rather than the fund. The table maps each layer to its article, its home and its template.

The website layer is where the other two meet. Article 10(1)(d) requires the website to carry the Article 11 periodic information. The ESAs expect managers to meet that duty by publishing the Annex II to V templates themselves (ESAs Q&A V.26). The RTS adds housekeeping that is easy to miss. Website information must show its publication date and any update date, and a downloadable file carries its version history in the file name (RTS Art. 2(3)).

Consistency across the layers is now an inspection point in its own right. The Central Bank gave its feedback on the ESMA common supervisory action in October 2025. It expects firms to review and approve the wording of all three layers regularly, and to document those reviews (Central Bank of Ireland CSA feedback report, October 2025, p. 15). The CSSF made the same kind of comparison in its review, testing periodic figures against pre-contractual commitments (CSSF CSA feedback report, section 3.3.2.1).

The classification in the prospectus decides the template. A fund that promotes environmental or social characteristics reports in the Annex IV template, attached as an annex to its annual report (RTS Art. 50). A fund with sustainable investment as its objective uses Annex V (RTS Art. 58). In both cases the main body of the annual report must carry a prominent statement that the sustainability information is in that annex.

The annex titles confirm the pairing. Annex IV covers products under Article 8(1), (2) and (2a) SFDR and Article 6 of the Taxonomy Regulation. Annex V covers Article 9(1) to (4a) SFDR and Article 5 of the Taxonomy Regulation (RTS Annexes IV and V). The template obligation has applied since 1 January 2023 (RTS Art. 68). The CSSF told Luxembourg managers that annual reports issued from that date must use the mandatory templates in an annex (CSSF communication, 27 July 2022).

A fund outside both categories still owes one sentence. Its periodic report carries the Article 7 statement that its investments "do not take into account the EU criteria" for sustainable activities (Taxonomy Regulation Art. 7).

Two documents in fund reporting are called "Annex IV", and they have nothing to do with each other. The SFDR Annex IV is the Article 8 periodic template in Delegated Regulation 2022/1288. The AIFMD Annex IV is the pro-forma reporting template for the transparency report to the regulator (Regulation 231/2013, Art. 110 and Annex IV), covered in the Annex IV reporting guide. The two share a name and nothing else.

Article 2(1) of the RTS lets a manager adapt the size, font and colours of the templates (RTS Art. 2(1)). Completing them follows the annexes themselves, including their instructions on which sections apply to a given product (RTS Annexes IV and V).

Both templates ask the same core questions, with Annex V asking for more evidence. The table above sets out the main sections that the RTS articles specify, with headings as the articles quote them. It is a map of those requirements, not a copy of the full template.

From the second report onwards, the attainment section and the taxonomy section each carry a historical comparison, under RTS Articles 51(c), 55(1)(b)(vii), 59(d) and 62(1)(b)(vii). It runs against each previous periodic report, up to at least the last five, with indicators reported consistently over time. It uses relative measures such as impact per euro invested, and notes which indicators an auditor or third party checked (RTS Art. 64).

The RTS does not say how "the period covered by the periodic report" is measured for top investments and proportions. Asked whether funds should use quarterly snapshots or a single year-end snapshot, the ESAs declined to impose a method. The periodic disclosures complement sectoral reporting, so the method follows the UCITS or AIFMD rules behind the annual report (ESAs Q&A V.30, published 4 August 2025). The ESAs' refusal to set one method points to those sectoral rules; it is not an open choice.

PAI indicators turn up in the template for three different reasons. The ESAs separate them. They are mandatory evidence for the "no significant harm" test on sustainable investments. They feed the product-level PAI consideration under SFDR Article 7. And they may, optionally, serve as the indicators that measure attainment (ESAs Q&A IV.22). The CSSF found some managers pasting the same PAI text into pre-contractual and periodic documents. Others listed PAI figures with no threshold or comparison, which the CSSF said investors find hard to read (CSSF CSA feedback report, section 3.3.2.2).

The numbers in this template are read against the prospectus. The CSSF treats the minimums in an Article 8 or 9 template as binding commitments, monitored by the depositary (CSSF SFDR FAQ, Q4). Its review compared reported sustainable and taxonomy-aligned shares with stated minimums, and some funds kept a wide buffer (CSSF CSA feedback report, section 3.3.2.1). The sample also held a fund in its ramp-up period, whose pre-contractual disclosures said the minimum did not apply during ramp-up and whose periodic report explained this (same section). A reported figure is read against the commitment and any condition the prospectus attached to it.

The PAI statement is the manager's annual account of the harm its investment decisions do to sustainability factors. It is an entity-level duty under SFDR Article 4, not a fund document. A manager either publishes a due-diligence statement on PAI, or publishes clear reasons why it does not consider adverse impacts. That choice ends above 500 employees. Article 4(3) makes the statement mandatory for a manager over that average headcount. Article 4(4) does the same for the parent of a large group, measured on a consolidated basis.

The group test counts heads across the whole group. The Commission's answer is that the headcount covers the parent and all subsidiaries, inside and outside the EU. The statement itself is adapted to the parent, not the group (ESAs Q&A IV.1). Who counts as an employee follows national law, since SFDR has no definition (Q&A IV.4).

The four quarter-end points do not need quarterly data from investee companies. In the ESAs' worked example, a manager in May 2026 takes the latest reported figures for fiscal 2025. It applies them to its holdings at each 2025 quarter-end and publishes before 30 June 2026 (ESAs Q&A IV.10). The statement covers every investment decision of the manager, including Article 6 funds and delegated portfolios (Q&A IV.9, IV.23 to IV.25). The CSSF flagged one sampled manager whose website limited the statement to its Article 8 and 9 funds (CSSF CSA feedback report, section 3.1.2.2).

Product-level PAI is a separate duty with a separate home. Where a manager considers PAI at entity level, each fund's pre-contractual document must explain whether and how that fund does so. It must also say the information is in the periodic report. Where the manager explains instead, each fund carries that statement and the reasons (SFDR Art. 7). A manager below the threshold that explains at entity level can still run a fund that pursues lower adverse impacts. In that case the pre-contractual and periodic disclosures must explain how the fund considered PAI (ESAs Q&A IV.2).

Plenty of firms take the explain route. The Central Bank found that a large portion of firms do not consider PAI at entity level, citing data (Central Bank CSA feedback report, p. 13). The reporting periods differ. The entity statement always covers the calendar year, while a fund's periodic annex covers the fund's financial year. A fund with a 31 March year-end reports over a different window and a different set of holdings. Its PAI figures can therefore differ from the manager's June statement (RTS Art. 51(a)).

The taxonomy-alignment figure is the share of the fund invested in activities that meet the EU Taxonomy's technical screening criteria. An Article 9 fund that invests in an environmental activity must report it under Taxonomy Regulation Article 5, including the shares in enabling and transitional activities. An Article 8 fund promoting environmental characteristics applies the same rule under Article 6. It must also carry a fixed statement that the "do no significant harm" principle applies only to the investments that take the EU criteria into account.

The formula is in RTS Article 17. The numerator is the market value of a closed list of aligned holdings. It takes the aligned share of company equity and debt, use-of-proceeds debt, EU green bonds, and aligned real estate and infrastructure. It also takes securitisations with aligned exposures and the aligned share of other Article 8 and 9 funds held. The calculation nets short positions using the short-selling regulation's method. The denominator is the market value of all investments.

That denominator is not NAV. The ESAs say "all investments" means the sum of all assets held, with no deduction for liabilities. Using NAV would overstate the share and could in theory push it past 100% (ESAs Q&A III.2). For a private credit fund the other key answer is that originated loans are treated like debt securities in this calculation (Q&A VII.15).

Pre-contractual and periodic templates use the key performance indicators differently. The pre-contractual minimum uses turnover, unless capital expenditure or operating expenditure gives a more representative picture and the manager explains why (RTS Art. 17(3) and (4)). The periodic report shows turnover, CapEx and OpEx for non-financial investees, and turnover and CapEx, where applicable, for financial ones. Insurers' non-life underwriting has its own treatment (RTS Art. 55(2)).

Two bar charts deal with sovereign exposure. The first includes sovereign bonds in the denominator; the second removes them from both numerator and denominator (RTS Art. 17(5) and Art. 55(1)(b)(ii) and (iii)). The ESAs' worked example in the table above shows the effect on a €200 fund (ESAs Q&A V.20, published 25 July 2024).

Note what stays in: cash sits in the denominator of both charts. Only sovereign exposure leaves, and only in the second chart. If the fund could not assess its sovereign exposures, it adds a narrative giving the reasons and the size of those exposures (RTS Art. 55(1)(b)(viii)).

The rest of the section follows RTS Article 55, which Article 62 applies to Article 9 funds. The fund names any auditor or third party that gave assurance on alignment and splits out transitional and enabling activities. It also explains any environmental sustainable investments that are not taxonomy-aligned. Since Delegated Regulation 2023/363, aligned fossil gas and nuclear activities are also shown separately in the charts (Art. 55(2)(d)).

Two Commission answers decide most edge cases. First, where a manager lacks reliable data on alignment, the pre-contractual and periodic figures "must indicate zero". The rules allow estimates only in exceptional cases, and they must be prudent and explained (ESAs Q&A VII.1). Second, the periodic report discloses the alignment actually reached in the period, whatever the commitment said. It shows the real level even when that beats the minimum (Q&A VII.1 and VII.8).

Zero is the common minimum. The Central Bank found that a significant majority of Article 8 and 9 funds it reviewed had a 0% minimum taxonomy commitment (Central Bank CSA feedback report, p. 13). The CSSF's sample showed the same pattern. The funds that did commit were mostly Article 9, with minimums from 1% to 60%, and all reported levels above them (CSSF CSA feedback report, section 3.3.2.1). A zero minimum does not mean a zero line in the annual report, however. If the fund held aligned assets during the year and has reliable data on them, the figure goes in.

"Do no significant harm" (DNSH) is two different tests that share a name. One qualifies a holding as a sustainable investment under SFDR. The other qualifies an economic activity as taxonomy-aligned. A fund can pass one and fail the other, and the periodic template asks about both.

The SFDR test gives managers latitude, but not over the evidence. The CSSF found that some managers had not used all 14 Table 1 indicators in their DNSH work, arguing irrelevance or missing data. It reminded them that the RTS requires every mandatory Table 1 indicator, plus relevant Table 2 and 3 ones (CSSF CSA feedback report, section 3.3.2.2). On the Taxonomy side, the ESAs say media-based controversy screens are not a proxy for activity-level DNSH. Compliance with local environmental law is not enough either where the local standards are lower (ESAs Q&A VII.12).

The two tests connect in one direction. The Commission's view is that sustainable investments include investments in environmentally sustainable activities within the meaning of the Taxonomy Regulation (ESAs Q&A V.1). The reverse does not hold: an Article 8 fund can make environmental sustainable investments that are not taxonomy-aligned (Q&A VII.19). One activity also counts towards only one objective in the report, so the same euro cannot appear under two (Q&A VII.16). The two tests draw on different evidence: PAI indicators for one, technical screening criteria for the other.

A fund that drops from Article 9 to Article 8 changes template, and with it the questions it must answer. Annex IV serves Article 8 disclosures and Annex V serves Article 9 ones (RTS Arts. 50 and 58). Those articles do not deal with a period that straddles the change. The table sets out what moves.

The change starts with the prospectus, and each regulator runs it through its standard review. In Luxembourg, the CSSF's SFDR FAQ, updated on 21 July 2026, lists a change in SFDR classification as a material change under Circular CSSF 14/591. The manager submits it for prior review through the e-Identification procedure for UCI prospectuses (CSSF SFDR FAQ, version 5, Q1). In Ireland, the Central Bank said reclassifications could not use its streamlined SFDR route and went through normal post-authorisation review (Central Bank process clarifications, February 2023). That streamlined route closed on 18 October 2024 (Central Bank notice, 27 September 2024).

The website moves at the same time. When a manager amends the Article 10 website information, it must publish a clear explanation of the amendment on the same website (SFDR Art. 12). If the relabel also changes the name, the ESMA fund-names guidelines apply on their own track (ESMA34-1592494965-657, 21 August 2024; summary in the fund-names rules).

The periodic report is where a mid-year relabel gets awkward. The RTS does not say which template covers a financial year that straddles the change. Nor do the comparison provisions say how a historical comparison treats earlier reports prepared on the other template (RTS Arts. 51(c), 59(d) and 64). Both points are open, and the To-verify block below records them.

The European Parliament's economic affairs committee voted on 10 September 2026 and decided to open negotiations with the Council. Its report was tabled for plenary on 15 September 2026, and the procedure awaits Parliament's first-reading position (Legislative Observatory, 2025/0361(COD)). Until an amending regulation is adopted and applies, the current Annex IV and V templates, the PAI statement and the 30 June date all stand.

The proposal does not itself amend any current obligation. Any change depends on the text finally adopted and its application provisions. The UK runs a separate regime. Its labelling and naming rules apply to UK UCITS and UK AIFs, and overseas-domiciled funds fall outside it. The FCA's anti-greenwashing rule applies to all authorised firms making sustainability claims (FCA SDR overview, updated 8 June 2026; summary in the UK SDR summary).