Matter Solution

Matter’s SFDR 2.0
Fund X-Ray

Helping you assess your funds against the SFDR 2.0 Proposal

On 20 November 2025, the European Commission proposed a comprehensive revision of the SFDR. The Proposal sets out an intention for SFDR 2.0 to have a “start-up period” from 2027 to 2028.

What are Matter clients doing to prepare?

  • Global positioning: How SFDR 2.0-aligned strategies can be marketed internationally, and where the key hurdles sit.
  • Category mapping: Map all ESG-labelled products to the proposed SFDR categories to confirm eligibility and compliance expectations.
  • Article 8/9 transition: Determine whether existing Article 8 and 9 funds should move to ESG Basics, Transition, or Sustainable.
  • Data readiness: Assess data availability for new requirements (e.g., minimum exclusions and eligible investment criteria), including reliance on external data and estimates.
  • Evolving governance: Upgrade controls so sustainability claims are backed by complete, verifiable data and remain clear and non-misleading.
Schedule a 20–30 min consultation

Review your Article 8/9 fund with Matter experts — data completeness, indicator alignment, and any gaps to address.

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How can Matter help?

Access Matter’s SFDR 2.0
Fund X-Ray

Three mandatory categories for financial products will potentially replace the current Article 8 and 9 SFDR designations - ‘Transition’, ‘ESG Basics’ and ‘Sustainable’.

The binding conditions vary between the three categories, but all include: (i) a mandatory minimum investment commitment aligned with the label (set at 70%); (ii) a compulsory list of exclusions.

Matter SFDR 2.0 Fund X-Ray can help: 

  • Assess your fund against the proposed product categories
  • Assess gaps against the minimum exclusions and thresholds requirements
  • Understand existing data gaps for new SFDR 2.0 elements


Matter Advisory - our advisory experts guide investors on how to manage potential gaps existing with your product status today.

Disclaimers

Matter SFDR 2.0 Fund X-Ray is not intended as investment or financial advice and does not provide assurance that a product or strategy passes or fails against the Proposals.

The proposal, FAQs, and impact assessment are available here: https://www.europarl.europa.eu/RegData/docs_autres_institutions/commission_europeenne/com/2025/0841/COM_COM(2025)0841_EN.pdf

It is important to note that the SFDR 2.0 Proposal is at an early legislative stage. Being a Level 1 regulation, it is subject to negotiation and potential amendment by the EU Parliament and the Council. As such, the final shape and requirements of SFDR 2.0 may change considerably before its adoption and entry into force. Until SFDR 2.0 starts applying (which will likely be 18 months after its entry into force), the current SFDR 1.0 framework remains fully applicable. Financial market participants should therefore continue to comply with existing requirements and are encouraged to stay informed of SFDR 2.0 legislative developments to anticipate future changes.