On 20 Nov 2025, the European Commission proposed SFDR 2.0. Matter discussed the shift from a disclosure regime to product categorisation with asset managers, and the roadmap ahead.
This paper examines the European Commission’s proposed revision of the Sustainable Finance Disclosure Regulation (SFDR 2.0) and what it means in practice for institutional investors and asset managers. Drawing on Matter’s regulatory expertise, product look-through capabilities, and direct discussions with multiple managers, the paper explains the shift from a disclosure regime towards a clearer product categorisation model—covering new categories, minimum exclusions, the 70% threshold, revised disclosure templates, and new marketing and naming rules.
Building on this analysis, the paper highlights where firms are likely to face the biggest operational and commercial pressure points (portfolio alignment, data/estimates governance, documentation readiness, and distribution implications), and where early preparation can reduce future rework. The paper includes real-world perspectives from leading managers and translates the proposals into practical steps—from fund “X-ray” screening and health checks, through commercial decision-making and governance upgrades, to implementation planning ahead of the new regime.
Importantly, the paper closes with clear pathways forward: how to build credible, defensible sustainability claims under increased scrutiny, and how institutional investors can use data and process discipline to strengthen classification readiness, reporting quality, and long-term category credibility.
This paper examines the European Commission’s proposed revision of the Sustainable Finance Disclosure Regulation (SFDR 2.0) and what it means in practice for institutional investors and asset managers. Drawing on Matter’s regulatory expertise, product look-through capabilities, and direct discussions with multiple managers, the paper explains the shift from a disclosure regime towards a clearer product categorisation model—covering new categories, minimum exclusions, the 70% threshold, revised disclosure templates, and new marketing and naming rules.
Building on this analysis, the paper highlights where firms are likely to face the biggest operational and commercial pressure points (portfolio alignment, data/estimates governance, documentation readiness, and distribution implications), and where early preparation can reduce future rework. The paper includes real-world perspectives from leading managers and translates the proposals into practical steps—from fund “X-ray” screening and health checks, through commercial decision-making and governance upgrades, to implementation planning ahead of the new regime.
Importantly, the paper closes with clear pathways forward: how to build credible, defensible sustainability claims under increased scrutiny, and how institutional investors can use data and process discipline to strengthen classification readiness, reporting quality, and long-term category credibility.
