On 10 March 2021, the Sustainable Finance Disclosure Regulation (SFDR, link) will enter into force. This means that fund managers (of AIFs, EuVECAs, EuSEFs, ELTIFs and UCITS) must, among other things, amend their prospectus to include sustainability information.

The AFM announced on 29 January 2021 (link, in Dutch) that fund managers will soon receive a request to submit the amended prospectuses to the AFM and to indicate where the sustainability information has been incorporated. The SFDR is relevant for every fund manager and applies to both ‘sustainable’ and ‘non-sustainable’ funds. Each prospectus should, in any case, include information on how sustainability risks are taken into account. There are additional information requirements applicable for ‘sustainable’ funds.

Fund managers must submit this information to the AFM by 10 March 2021. The survey is conducted among all Dutch fund managers (with the exception of small managers who fall under the light regime). The AFM has indicated that no prior approval from the AFM is required for changes in the prospectus made under the SFDR. On the basis of this announcement, it is not clear how the AFM will deal with ‘closed’ funds (e.g. closed-end funds or already closed open-end funds).

We recommend fund managers to make the relevant changes to the prospectus as soon as possible. We believe that a fund manager should not wait too long before making these fundamental choices.

For more information about the SFDR and what this means for your organisation, you can always contact one of our specialists.