EU SFDR Regulatory Technical Standards—FAQs

Copyright © 2025 LexisNexis
Produced in partnership with Daniel D’Ambrosio of Kirkland & Ellis International LLP , Rhys Davies of Kirkland & Ellis International LLP , Revathi Raghavan of Paul, Weiss, Rifkind, Wharton & Garrison LLP and Andy Burnett of Kirkland & Ellis International LLP
Practice notes

EU SFDR Regulatory Technical Standards—FAQs

Copyright © 2025 LexisNexis

Produced in partnership with Daniel D’Ambrosio of Kirkland & Ellis International LLP , Rhys Davies of Kirkland & Ellis International LLP , Revathi Raghavan of Paul, Weiss, Rifkind, Wharton & Garrison LLP and Andy Burnett of Kirkland & Ellis International LLP

Practice notes
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These Q&As answer some of the most frequently asked questions on the EU Sustainable Finance Disclosure Regulation (EU SFDR) (Regulation (EU) 2019/2088, as amended by Regulation (EU) 2020/852) regulatory technical standards (RTS). These Q&As cover, among other, product classification; Article 8 characteristics; principal adverse impact (PAI) data collection; use of third-party data; human rights due diligence and impact on non-EU managers.

On 6 April 2022, the European Commission adopted the final Regulatory Technical Standards (RTS) supplementing the EU Sustainable Finance Disclosure Regulation (EU SFDR) (Regulation (EU) 2019/2088, as amended by the EU Taxonomy Regulation (EU) 2020/852) and its Annexes. EU SFDR imposes significant ESG disclosure obligations on asset managers marketing funds in the EU. The RTS specify the mandatory website, pre-contractual and periodic reporting templates for financial market participants and in-scope financial products. For more information, see Commission publishes adopted RTS containing

Daniel D’Ambrosio
Daniel D’Ambrosio

Partner, Kirkland & Ellis International LLP

Dan’s practice focuses on counselling clients on ESG and sustainability matters across a range of corporate, fund formation and sustainable finance transactions, regulatory compliance matters and complex ESG disputes and crises. Dan has supported private equity clients globally to navigate emerging ESG regulatory frameworks such as SFDR and EU Taxonomy and translate requirements into strategy, governance, policies and risk management processes as well as downstream M&A transactions.

Dan has significant experience advising private equity clients, corporations, project sponsors and lenders on human rights matters and compliance with international frameworks such as the OECD Guidelines, UN Guiding Principles on Business and Human Rights, the Equator Principles and the IFC Performance Standards.


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Rhys Davies
Rhys Davies

Partner, Kirkland & Ellis International LLP

Rhys Davies is a partner in the ESG & Impact Practice Group in the London office of Kirkland & Ellis International LLP. Rhys has more than 15 years of ESG experience, including advising private equity firms, public companies and project sponsors in relation to the design and implementation of ESG strategies across a range of sectors, including energy and natural resources, infrastructure, real estate and technology.

Rhys' experience includes advising on sustainable finance disclosures (including pursuant to the EU Sustainable Finance Disclosure Regulation), green taxonomies, sustainability reporting, climate change, biodiversity loss, human rights and responsible business practices. He has assisted clients to develop and review ESG-related governance measures, policies, strategies, metrics and disclosures in a number of jurisdictions under both mandatory and voluntary frameworks.

Rhys also has broad environmental and social regulatory experience, including in relation to environmental impact assessment, emissions licensing, contaminated land, natural resources, indigenous engagement and cultural heritage. He has represented clients in both transactional settings and proceedings before administrative decision-makers, panels, tribunals and superior courts.

In addition to his undergraduate qualifications, Rhys holds a postgraduate certificate in Sustainable Business from the University of Cambridge and a FSA credential issued by the Sustainability Accounting Standards Board. Rhys is a former member of the Governance and Advisory Board for the Australian National Contact Point under the OECD Guidelines for Multinational Enterprises.

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Revathi Raghavan
Revathi Raghavan

Partner, Paul, Weiss, Rifkind, Wharton & Garrison LLP

Reva has extensive experience in advising sponsors on the regulatory aspects of fund formation and the regulations governing fund sponsors across all major alternative investment strategies. In particular, Reva advises on a broad range of EU and UK financial services regulations, including the UK Senior Managers and Certification Regime (SMCR), the Investment Firms Prudential Regime (IFPR), the UK Market Abuse Regulation (MAR), the EU Markets in Financial Instruments Directive II (MiFID II), the Alternative Investment Fund Managers Directive (AIFMD), SFDR, and the Taxonomy Regulation.

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Andy Burnett
Andy Burnett

Associate, Kirkland & Ellis International LLP

Andy is an associate in the London office of Kirkland & Ellis International LLP and a member of the Firm’s ESG & Impact Practice Group, which advises private equity firms, corporations, project sponsors and lenders on complex and evolving legal issues relating to environmental, social and governance (ESG) and climate-related regulatory requirements, investor demands, strategic opportunities, and voluntary reporting frameworks and coalitions.

He advises across the full range of ESG legal services, including ESG-linked private and public market financings, fund formation mandates, and corporate M&A transactions. He has advised funds on the application of the Sustainable Finance Disclosure Regulation to the categorization, strategy and operational risk and opportunity management programs of their alternative investment funds. As part of this work, he has helped establish market-leading ESG-driven Article 9 funds and is particularly interested in the development of impact strategies.

Andy also supports clients in navigating the evolving business and human rights landscape, including in relation to modern slavery, diversity and inclusivity and soft law standards like the OECD Guidelines and UN Guiding Principles on Business and Human Rights. Andy is qualified in England & Wales.

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Commission definition
What does Commission mean?

In the context of the bribery Act 2010, a commission is the giving of a financial advantage, although it is not necessarily a bribe.

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