SFDR Principal Adverse Impacts Statement Template (EU 2022/1288 Annex I)
SFDR Article 4 entity PAI statement: applicability, summary, Table 1 indicators 1-18, Table 2/3 picks, actions, policies, engagement, history, data controls
Як використовувати: Use it when an EU financial market participant must publish, or chooses to publish, its annual statement on principal adverse impacts by 30 June. Fill the applicability decision (500-employee test, group test) and the quarter-end holdings data first, then the indicator table and actions. The main pitfall is averaging only the year-end value instead of the four quarter ends, or mixing the EVIC and revenue denominators.
Перегляд
Principal Adverse Impacts Statement: [Financial market participant name]
Entity-level statement on principal adverse impacts (PAI) of investment decisions on sustainability factors, prepared under Article 4 of the Sustainable Finance Disclosure Regulation (SFDR, Regulation (EU) 2019/2088) and Articles 4 to 10 and Annex I of Commission Delegated Regulation (EU) 2022/1288 (the SFDR RTS, applicable from 1 January 2023), as in force in October 2026. It covers the applicability decision, the summary, the 18 mandatory Table 1 indicators, the additional Table 2 and Table 3 indicators, actions taken and planned, policies, engagement, international standards, historical comparison, calculation methodology and the data controls behind every figure. SFDR 2.0, the Commission proposal COM(2025) 841 to amend Regulation (EU) 2019/2088, is a proposal and not law as of 2026-10: the European Parliament and the Council have adopted their negotiating positions and trilogue negotiations are under way; check the current status. The proposal would remove this entity-level statement; the current regime applies until amending legislation is adopted and applies. Replace every
[bracketed]value and every row marked Example. Obtain the regulation and the delegated regulation for the normative text and check the consolidated versions on EUR-Lex. This is a document format, not legal, investment or regulatory advice.
Document control
| Field | Value |
|---|---|
| Document ID | [SFDR-PAI-2026] |
| Financial market participant | [Legal name], LEI [LEI code] |
| SFDR category of financial market participant | [Investment firm providing portfolio management / AIFM / UCITS management company / Credit institution providing portfolio management / Insurer offering IBIPs / Other under SFDR Article 2(1)] |
| Basis for the statement | [Article 4(1)(a) voluntary / Article 4(3) more than 500 employees / Article 4(4) parent of a large group] |
| Consolidated statement covers | [Entity only / Entity and subsidiaries: list] |
| Reference period | 1 January [year n] to 31 December [year n] |
| Publication deadline | 30 June [year n+1] |
| Website section | Sustainability-related disclosures, separate section titled "Statement on principal adverse impacts of investment decisions on sustainability factors" |
| Version | [1.0] |
| Status | [Draft / In review / Approved by governing body / Published / Superseded] |
| Owner | [@head-of-sustainability] |
| Approvers/reviewers | [@management-board], [@compliance], [@risk], [@data-office], [@legal] |
| Last updated | YYYY-MM-DD |
| Date of publication on website | YYYY-MM-DD |
| Classification | [Public once published; internal sections Confidential] |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| Governing body (approval of PAI policies, RTS Article 7(1)(a)) | [@name] | [Approve / Approve with conditions / Reject] | YYYY-MM-DD |
| Head of Sustainability (preparer) | [@name] | [Decision] | YYYY-MM-DD |
| Compliance (regulatory review) | [@name] | [Decision] | YYYY-MM-DD |
| Chief Data Officer (data sign-off) | [@name] | [Decision] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change |
|---|---|---|---|
| 0.1 (Example) | 2027-03-15 | [@sustainability-analyst] | First draft of the statement for reference period 2026 |
| 1.0 (Example) | 2027-06-24 | [@management-board] | Approved and published on website (file name suffix v1.0) |
| [x.y] | YYYY-MM-DD | [@name] | [Change summary, including any post-publication correction] |
Contents
- 1. Scope, applicability and route
- 2. Publication and presentation requirements
- 3. Summary
- 4. Description of the principal adverse impacts on sustainability factors
- 5. Calculation methodology
- 6. Description of policies to identify and prioritise principal adverse impacts
- 7. Engagement policies
- 8. References to international standards
- 9. Historical comparison
- 10. Data governance and controls
- 11. Link to product-level disclosures
- 12. Production workflow and calendar
- 13. Alternative: no consideration statement
- 14. Regulatory change watch
- 15. Glossary
- 16. References
- Standard and licence note
1. Scope, applicability and route
Article 4 of SFDR gives a financial market participant two options: consider principal adverse impacts and publish a statement on its due diligence policies for them (Article 4(1)(a)), or explain clearly why it does not consider them and whether and when it intends to (Article 4(1)(b)). Two groups lose the option to explain and must publish the statement: participants that exceed an average of 500 employees during the financial year, measured on the balance sheet date (Article 4(3)), and participants that are parent undertakings of a large group, where the group exceeds that average on a consolidated basis (Article 4(4)). Both obligations have applied since 30 June 2021.
1.1 Applicability decision
| Test | Evidence | Result |
|---|---|---|
| Is the entity a financial market participant under SFDR Article 2(1)? | [Licence type and register entry] | [Yes / No] |
| Average number of employees during the last financial year, entity level | [HR report reference, balance sheet date] | [Number] |
| Is the entity the parent undertaking of a large group (Directive 2013/34/EU Article 3(7))? | [Group structure chart reference] | [Yes / No] |
| Average number of employees of the group, consolidated | [Consolidation report reference] | [Number] |
| Route chosen | [Mandatory under Article 4(3) / Mandatory under Article 4(4) / Voluntary under Article 4(1)(a) / No consideration under Article 4(1)(b)] | [Route] |
| Example: Kestrel Bay Capital Europe | HR report 2026, balance sheet date 2026-12-31 | 620 average employees, mandatory under Article 4(3) |
Record the decision even when the result is obvious. If the employee count falls below 500 in a later year, the firm moves back to comply or explain, and the change of route must be reasoned and dated rather than silent.
1.2 Entities and investments in scope
List every legal entity covered by a consolidated statement. The Annex I template allows one statement for the participant and its named subsidiaries. State which investment decisions are in scope: discretionary portfolio management mandates, funds managed by the entity, own-account investments of an insurer backing insurance-based investment products, or a combination.
| Entity or business line | Role | Assets in scope (EUR million, 31 December) | Included |
|---|---|---|---|
| Kestrel Bay Capital Europe, discretionary mandates, including the EUR 1,080 million Northwold Retirement Scheme OCIO mandate (Example) | Portfolio manager | 2,100 | Yes |
| Kestrel Bay Capital Europe, UCITS funds under delegation (Example) | Delegated portfolio manager | 1,100 | Yes, decisions made by the entity |
| [Subsidiary name] | [Role] | [Amount] | [Yes / No, reason] |
| Total in scope (equals the entity's assets under management of EUR 3,200 million) (Example) | 3,200 |
State the treatment of derivatives, cash, funds of funds (look-through or not) and assets for which the participant has no investment discretion, and keep that treatment stable from year to year. Financial advisers publish a different statement under RTS Article 11 with its own title; if the entity also gives investment advice, keep that statement in a separate document and cross-refer to it here.
2. Publication and presentation requirements
| Requirement | Basis | How it is met | Owner |
|---|---|---|---|
| Publish by 30 June each year, covering 1 January to 31 December of the previous year | RTS Article 4(1) | [Publication date planned] | [@owner] |
| First statement covers from the date PAI were first considered to 31 December, published by 30 June of the following year | RTS Article 4(3) | [Applies / Not applicable] | [@owner] |
| Separate website section with the prescribed title, inside the "Sustainability-related disclosures" section | RTS Articles 4(1) and 23 | [URL] | [@web-owner] |
| Use the Table 1 template of Annex I | RTS Article 4(2) | Sections 3 to 9 follow Table 1 order | [@owner] |
| Information free of charge, easily accessible, prominent, concise, fair, clear and not misleading; readable layout | RTS Article 2(1) | [Design review record] | [@owner] |
| Searchable electronic format | RTS Article 2(2) | HTML page and searchable PDF | [@web-owner] |
| Keep up to date, show date of publication and of any update; version history in the file name of a download | RTS Article 2(3) | File name pattern [entity]-pai-statement-[year]-v[x.y].pdf | [@web-owner] |
| Give LEIs and ISINs where available when naming entities or products | RTS Article 2(4) | LEI in header | [@owner] |
| Summary in an official language of the home Member State, plus a customary international finance language where different, plus a host Member State language where a product is made available there | RTS Article 5 | [Languages list] | [@translation-owner] |
| Summary at most two A4 pages when printed | RTS Article 5 | [Page count check] | [@owner] |
| Statement maintained on the website (publish and maintain) | SFDR Article 4(1) | Archive of previous years kept online | [@web-owner] |
Archive previous statements in the same section. Article 10 of the RTS requires comparison with earlier periods, and readers expect to find the earlier statements to check the comparison.
3. Summary
The summary must name the participant, state that principal adverse impacts are considered, give the reference period and summarise the principal adverse impacts. Use the following structure and translate it into each language required in section 2.
Statement header. [Financial market participant name] (LEI [code]) considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of [name] [and its subsidiaries, namely: list]. This statement covers the reference period from 1 January [year n] to 31 December [year n].
Summary of principal adverse impacts. Describe in plain language, in about 400 to 800 words:
- the three to five adverse impacts the firm prioritised and why (severity, probability, irremediable character, materiality to the portfolios);
- the direction of change against the previous period for each prioritised indicator, with the main driver (portfolio change, data coverage change, issuer behaviour or methodology change);
- the main actions taken during the period (engagement, voting, exclusions, portfolio construction) and the actions planned or targets set for the next period;
- data coverage limits that a reader needs to interpret the figures.
Example (extract): "Kestrel Bay Capital Europe prioritised greenhouse gas emissions (indicators 1 to 3), exposure to the fossil fuel sector (indicator 4), violations of the UN Global Compact principles and OECD Guidelines for Multinational Enterprises (indicator 10) and board gender diversity (indicator 13). The carbon footprint of investments in investee companies fell from 131 to 118 tonnes CO2 equivalent per EUR million invested, mainly because of portfolio reallocation in the utilities sector. Exposure to companies active in the fossil fuel sector averaged 3.5% of investments over the four quarter-end dates. The firm engaged with 42 investee companies on climate transition plans and escalated two engagements through voting against directors."
4. Description of the principal adverse impacts on sustainability factors
The Annex I table has five columns after the indicator: metric, impact for the reference year, impact for the previous year, explanation, and actions taken with actions planned and targets set for the next reference period. Keep the regulation's numbering (1 to 18 in Table 1) so that readers can compare statements across firms.
Conventions for this section: currency EUR; "per EUR million invested" uses the current value of all investments as the denominator unless the indicator says otherwise; impacts are the average of the values on 31 March, 30 June, 30 September and 31 December (RTS Article 6(3)); data coverage is the share of the relevant investments, by value, for which reported or estimated data was available.
4.1 Indicators applicable to investments in investee companies
| No. | Adverse sustainability indicator | Metric (short form) | Impact year n | Impact year n-1 | Coverage | Explanation | Actions taken, planned and targets |
|---|---|---|---|---|---|---|---|
| 1 | GHG emissions | Scope 1, Scope 2, Scope 3 and total attributed emissions (tCO2e) | Scope 1: 198,400 (Example); Scope 2: 38,400 (Example); Scope 3: 147,200 (Example); Total: 384,000 (Example, entity level, average of four quarters, section 5.2) | Total: 425,600 (Example) | 91% (Example) | [Drivers of change; share of Scope 3 that is estimated] | ACT-001, ACT-002 |
| 2 | Carbon footprint | Attributed emissions per EUR million invested | 118 (Example, Q4 value used in section 5) | 131 (Example) | 91% (Example) | [Explanation] | ACT-001 |
| 3 | GHG intensity of investee companies | Emissions per EUR million of investee revenue, weighted by portfolio share | 183 (Example, Q4 value) | 197 (Example) | 91% (Example) | [Explanation] | ACT-001 |
| 4 | Exposure to companies active in the fossil fuel sector | Share of investments in such companies | 3.5% (Example) | 4.4% (Example) | 95% (Example) | [Explanation; Annex I counts a company with any fossil fuel revenue] | ACT-003 |
| 5 | Share of non-renewable energy consumption and production | Non-renewable share of investee energy consumption and production, as a percentage of total energy sources | [x%] | [x%] | [x%] | [Explanation] | [Action IDs] |
| 6 | Energy consumption intensity per high impact climate sector | GWh per EUR million of investee revenue, per NACE sector A to H and L | [Value per sector] | [Value per sector] | [x%] | [Explanation] | [Action IDs] |
| 7 | Activities negatively affecting biodiversity-sensitive areas | Share of investments in investee companies with sites in or near such areas that negatively affect them | [x%] | [x%] | [x%] | [Explanation] | [Action IDs] |
| 8 | Emissions to water | Tonnes per EUR million invested, weighted average | [Value] | [Value] | [x%] | [Explanation] | [Action IDs] |
| 9 | Hazardous waste and radioactive waste ratio | Tonnes per EUR million invested, weighted average | [Value] | [Value] | [x%] | [Explanation] | [Action IDs] |
| 10 | Violations of UN Global Compact principles and OECD Guidelines for Multinational Enterprises | Share of investments in investee companies involved in violations | 0.8% (Example) | 1.2% (Example) | 98% (Example) | [Explanation, screening provider and policy] | ACT-004 |
| 11 | Lack of processes and compliance mechanisms to monitor compliance with the UN Global Compact principles and OECD Guidelines | Share of investments in investee companies without such policies or grievance mechanisms | [x%] | [x%] | [x%] | [Explanation] | [Action IDs] |
| 12 | Unadjusted gender pay gap | Average gap of investee companies | [x%] | [x%] | [x%] | [Explanation, low coverage outside the EU] | [Action IDs] |
| 13 | Board gender diversity | Average ratio of female to male board members, as a percentage of all board members | 36% (Example) | 33% (Example) | 97% (Example) | [Explanation] | ACT-005 |
| 14 | Exposure to controversial weapons | Share of investments in investee companies involved in manufacture or selling of anti-personnel mines, cluster munitions, chemical or biological weapons | 0.0% (Example) | 0.0% (Example) | 100% (Example) | Excluded by policy | ACT-006 |
4.2 Indicators applicable to investments in sovereigns, supranationals and real estate assets
Indicators 15 and 16 apply to sovereign and supranational investments; indicators 17 and 18 apply to real estate assets. Where the firm holds no investment in a category, say so in the explanation instead of deleting the rows. A reader cannot tell a missing row from an omission.
| No. | Adverse sustainability indicator | Metric (short form) | Impact year n | Impact year n-1 | Coverage | Explanation | Actions taken, planned and targets |
|---|---|---|---|---|---|---|---|
| 15 | GHG intensity | GHG intensity of investee countries (emissions per EUR million of GDP, weighted by portfolio share) | [Value] | [Value] | [x%] | [Explanation, emissions scope used for countries] | [Action IDs] |
| 16 | Investee countries subject to social violations | Absolute number and number relative to all investee countries | [n; x%] | [n; x%] | [x%] | [Source of the list of violations used] | [Action IDs] |
| 17 | Exposure to fossil fuels through real estate assets | Share of investments in real estate assets involved in extraction, storage, transport or manufacture of fossil fuels | [x% / Not applicable: no direct real estate] | [x%] | [x%] | [Explanation] | [Action IDs] |
| 18 | Exposure to energy-inefficient real estate assets | Share of investments in energy-inefficient real estate assets, using the Annex I formula | [x% / Not applicable] | [x%] | [x%] | [EPC and NZEB basis used] | [Action IDs] |
4.3 Additional climate and other environment-related indicators (Table 2)
Select at least one indicator from Table 2 of Annex I. Record why it was chosen: the selection must follow the methodology in section 6, not data convenience alone.
| Table 2 No. | Indicator | Metric | Impact year n | Impact year n-1 | Why selected | Actions |
|---|---|---|---|---|---|---|
| 4 (Example) | Investments in companies without carbon emission reduction initiatives | Share of investments in investee companies without initiatives aimed at aligning with the Paris Agreement | 27% (Example) | 34% (Example) | Supports the climate engagement priority | ACT-002 |
| [No.] | [Indicator] | [Metric] | [Value] | [Value] | [Reason] | [Action IDs] |
4.4 Additional social, human rights and anti-corruption indicators (Table 3)
Select at least one indicator from Table 3 of Annex I.
| Table 3 No. | Indicator | Metric | Impact year n | Impact year n-1 | Why selected | Actions |
|---|---|---|---|---|---|---|
| 9 (Example) | Lack of a human rights policy | Share of investments in entities without a human rights policy | 12% (Example) | 15% (Example) | High severity in supply-chain-intensive sectors held | ACT-004 |
| [No.] | [Indicator] | [Metric] | [Value] | [Value] | [Reason] | [Action IDs] |
Other indicators. Add any further indicator the firm uses to identify and assess additional principal adverse impacts (RTS Article 6(1)(c)), in the Table 2 or Table 3 format. Define the metric precisely, name the data source and state whether the value is reported or estimated.
4.5 Actions taken, actions planned and targets
RTS Article 6(2) asks for the actions taken during the reference period and the actions planned or targets set for the next period to avoid or reduce the principal adverse impacts. Each action has an ID so that the indicator tables, the engagement section and next year's comparison can refer to it.
| Action ID | Indicators addressed | Action taken in year n | Action planned or target for year n+1 | Measure of progress | Owner |
|---|---|---|---|---|---|
| ACT-001 (Example) | 1, 2, 3 | Reallocated utilities exposure towards issuers with validated transition plans | Reduce carbon footprint of discretionary mandates by 7% against the year n figure | Indicator 2 at year end | [@cio] |
| ACT-002 (Example) | 1, Table 2 No. 4 | Engaged 42 issuers on transition plans | Engage the 30 largest contributors to attributed emissions | Share of contributors with targets | [@stewardship-lead] |
| ACT-003 (Example) | 4 | Applied revenue-based thermal coal exclusion | Review oil and gas exclusion thresholds | Indicator 4 trend | [@sustainability-lead] |
| ACT-004 (Example) | 10, Table 3 No. 9 | Watch list for issuers flagged by the norms screening provider; two divestments | Escalate engagement within 12 months of a flag, then divest | Number of unresolved flags | [@stewardship-lead] |
| ACT-005 (Example) | 13 | Voted against nomination committee chairs where the board had fewer than 30% women | Keep the voting policy, extend it to Asian markets | Votes cast in line with the policy | [@voting-lead] |
| ACT-006 (Example) | 14 | Firm-wide exclusion maintained | Continue; quarterly screening | Zero exposure confirmed | [@compliance] |
Targets marked Example are illustrations only. Set real targets through the governance route in section 6 and avoid targets that depend only on data coverage improving.
5. Calculation methodology
Annex I of the SFDR RTS sets formulas for GHG emissions, carbon footprint, GHG intensity of investee companies, GHG intensity of sovereigns and inefficient real estate assets. The formulas below restate them in notation; check the Annex for the authoritative form.
Definitions used by the formulas: the current value of an investment is the value in EUR of the firm's investment in the investee; enterprise value (EVIC) is the sum at the investee's fiscal year end of the market capitalisation of ordinary and preferred shares and the book value of total debt and non-controlling interests, with no deduction for cash; the current value of all investments is the EUR value of all the firm's investments.
Attributed GHG emissions of the portfolio, for each scope:
Carbon footprint, in tCO2e per EUR million invested:
GHG intensity of investee companies, in tCO2e per EUR million of revenue:
Here is the current value of the investment in company (EUR million), the current value of all investments (EUR million), the Scope 1, 2 and 3 emissions of company in tCO2e, and its revenue in EUR million. The sovereign GHG intensity (indicator 15) follows the same weighting with country emissions divided by GDP in EUR million.
5.1 Worked example: one quarter-end date
Example: a simplified mandate of Kestrel Bay Capital Europe on 31 December, total investments EUR 50 million, of which EUR 45 million in three investee companies and EUR 5 million in cash.
| Holding | Value (EUR m) | EVIC (EUR m) | Scope 1+2+3 (tCO2e) | Revenue (EUR m) | Ownership share | Attributed tCO2e | Portfolio weight | Revenue intensity | Weighted intensity |
|---|---|---|---|---|---|---|---|---|---|
| Company A (Example) | 20 | 4,000 | 800,000 | 2,500 | 0.50% | 4,000 | 40% | 320 | 128 |
| Company B (Example) | 15 | 1,500 | 150,000 | 1,000 | 1.00% | 1,500 | 30% | 150 | 45 |
| Company C (Example) | 10 | 500 | 20,000 | 400 | 2.00% | 400 | 20% | 50 | 10 |
| Cash (Example) | 5 | n/a | n/a | n/a | n/a | 0 | 10% | n/a | 0 |
| Total (Example) | 50 | 5,900 | 100% | 183 |
Results for this date: attributed emissions 5,900 tCO2e; carbon footprint 5,900 / 50 = 118 tCO2e per EUR million invested; GHG intensity 128 + 45 + 10 = 183 tCO2e per EUR million of revenue. Cash contributes nothing to the numerator but stays in the denominator. In this Example the simplified mandate is taken as representative of the whole entity: applying its footprint to the EUR 3,200 million in scope (section 1.2) gives the entity-level 31 December value of 118 x 3,200 = 377,600 tCO2e used in section 5.2. In a real statement, sum the attributed emissions of every holding in scope. Document how the firm treats holdings without data and check the current ESAs questions and answers on the denominator and on coverage.
5.2 Worked example: quarterly averaging
The Impact column reports the average of the four quarter-end values (RTS Article 6(3)).
| Indicator | 31 March | 30 June | 30 September | 31 December | Average (Impact year n) |
|---|---|---|---|---|---|
| Total attributed GHG emissions, tCO2e (Example, entity level, EUR 3,200 million in scope) | 396,800 | 387,200 | 374,400 | 377,600 | 384,000 |
| Exposure to fossil fuel sector, % (Example) | 4.0% | 3.6% | 3.2% | 3.2% | 3.5% |
Check: (396,800 + 387,200 + 374,400 + 377,600) / 4 = 1,536,000 / 4 = 384,000; the 31 December value equals the section 5.1 footprint applied to the assets in scope (118 x 3,200 = 377,600); and (4.0 + 3.6 + 3.2 + 3.2) / 4 = 14.0 / 4 = 3.5%. In section 4.1 the carbon footprint and intensity Example values show the 31 December figure from section 5.1 for traceability; in the real statement report the four-quarter average.
5.3 Methodology choices to document
| Choice | Option chosen | Rationale | Changed since last period |
|---|---|---|---|
| Emissions data hierarchy | [Reported, then vendor estimate, then sector proxy] | [Reason] | [Yes / No] |
| Scope 3 categories included | [All categories reported or estimated by vendor] | [Reason] | [Yes / No] |
| EVIC date | [Investee fiscal year end, latest available at quarter end] | [Reason] | [Yes / No] |
| Currency conversion | [ECB reference rate at the investee's fiscal year end] | [Reason] | [Yes / No] |
| Funds held | [Look-through where holdings are available, otherwise excluded and disclosed] | [Reason] | [Yes / No] |
| Derivatives | [Treatment and reason] | [Reason] | [Yes / No] |
| Missing data | [Excluded from numerator, kept in denominator, coverage disclosed] | [Reason] | [Yes / No] |
Explain each change in the indicator's explanation column and in the historical comparison, and restate the previous year where practical.
6. Description of policies to identify and prioritise principal adverse impacts
| RTS Article 7 element | Content to provide | Entry |
|---|---|---|
| 7(1)(a) Date of governing body approval of the policies | Date and body | [Management board, YYYY-MM-DD] |
| 7(1)(b) Allocation of responsibility for implementation | Roles in strategy and procedures | [CIO owns integration, Sustainability owns methodology, Risk owns monitoring, Compliance owns disclosure] |
| 7(1)(c) Methodology to select additional indicators and to identify and assess PAI, including probability, severity and irremediable character | Method description | [See 6.1] |
| 7(1)(d) Margin of error in the methodology | Size and explanation | [See 6.2] |
| 7(1)(e) Data sources | List | [See 6.3] |
| 7(2) Best efforts where data is not readily available | Direct requests, research, providers, experts, reasonable assumptions | [See the best efforts paragraph] |
6.1 Identification and prioritisation method
Describe how the firm moves from the full indicator set to the principal adverse impacts it acts on. A clear method has four steps: measure every mandatory indicator at portfolio and issuer level; screen issuers against thresholds and norms-based flags; score each adverse impact for severity (scale, scope, irremediable character) and for probability; and prioritise the impacts and issuers with the highest combined scores for action.
| Prioritisation criterion | Scale | Applied to | Example result |
|---|---|---|---|
| Severity: scale of harm | 1 to 5 | Each indicator and issuer | Climate indicators rated 5 (Example) |
| Severity: scope (people or area affected) | 1 to 5 | Each indicator and issuer | [Result] |
| Irremediable character | Yes / No, raises priority | Each impact | Biodiversity loss flagged irremediable (Example) |
| Probability of occurrence | 1 to 5, for potential impacts | Forward-looking assessments | [Result] |
| Exposure of the firm's portfolios | Share of assets | Each indicator | [Result] |
Explain the link to the firm's double materiality work where the group also reports under the European Sustainability
Reporting Standards; see the Double Materiality Assessment (finance/sustainability-double-materiality-assessment).
6.2 Margin of error
Quantify where possible. Example: "Scope 3 emissions are estimated by the data provider for 64% of covered issuers; the provider states a typical range of plus or minus 30% around estimated values; total attributed emissions are therefore subject to a margin of error that we estimate at plus or minus 15%." State how the margin was derived and which indicators are most affected.
6.3 Data sources
| Source ID | Provider or source | Indicators | Reported or estimated | Contract or licence reference |
|---|---|---|---|---|
| SRC-01 (Example) | [ESG data vendor A] | 1 to 9, Table 2 No. 4 | Mixed, estimate flag provided | [Contract ref] |
| SRC-02 (Example) | [Norms screening vendor B] | 10, 11, 14 | Research-based assessment | [Contract ref] |
| SRC-03 (Example) | Investee company reports, including sustainability statements under CSRD where available | 12, 13, Table 3 No. 9 | Reported | Public |
| [SRC-NN] | [Source] | [Indicators] | [Type] | [Reference] |
Best efforts for missing data. Record the actions taken where data is not readily available: direct requests to investee companies, additional research, cooperation with third-party providers or external experts, and reasonable assumptions. Give the number of requests sent, the response rate and the assumptions used, so that the reader can judge the effort.
7. Engagement policies
Provide brief summaries of the engagement policy under Article 3g of the Shareholder Rights Directive (Directive 2007/36/EC, as amended by Directive (EU) 2017/828), where it applies, and of any other engagement policy used to reduce principal adverse impacts.
| Engagement policy | Indicators covered | Escalation where no reduction over more than one period | Link |
|---|---|---|---|
| Shareholder engagement policy (Article 3g) (Example) | 1 to 4, 10, 13 | Collaborative engagement, then votes against directors, then reduction or divestment after 24 months without progress | [URL to policy] |
| Fixed income issuer engagement (Example) | 1 to 3, Table 2 No. 4 | Pricing and allocation decisions in new issues; exclusion from buy list | [URL] |
| Proxy voting policy | [Indicators] | [Escalation] | Proxy Voting Policy (compliance/proxy-voting-policy) |
Keep the engagement records (issuer, indicator, objective, status, next step) in the stewardship log and report outcomes in the Stewardship Report (finance/stewardship-report) and keep only a summary here.
8. References to international standards
| Code or standard (name only) | Adherence or use | Indicators that measure it | Methodology and data |
|---|---|---|---|
| OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (Example) | Due diligence framework for investee screening | 10, 11 | Norms-based screening by SRC-02 |
| UN Global Compact principles (Example) | Screening reference | 10, 11 | SRC-02 |
| UN Guiding Principles on Business and Human Rights (Example) | Human rights due diligence expectations | Table 3 No. 9 | SRC-03 |
| Principles for Responsible Investment (signatory status) (Example) | Firm is a signatory | Not indicator-based | Annual reporting |
| Paris Agreement alignment (Example) | Portfolio temperature and target coverage assessed | 1 to 3, Table 2 No. 4 | [Methodology name and provider] |
| [Code or standard] | [Use] | [Indicators] | [Method] |
8.1 Forward-looking climate scenario
| Question | Answer |
|---|---|
| Is a forward-looking climate scenario used? | [Yes / No] |
| Scenario name and provider | [Name, provider] |
| When the scenario was designed | [Year or date] |
| Scope of coverage and data sources | [Share of portfolio covered, sources] |
| How the methodology forecasts investee impacts | [Description] |
| If no scenario is used, why the firm considers it irrelevant | [Reason, required by RTS Article 9(2)(d)] |
9. Historical comparison
| Indicator | Year n | Year n-1 | Year n-2 | Year n-3 | Year n-4 | Year n-5 | Main driver of change in year n |
|---|---|---|---|---|---|---|---|
| 1 Total GHG emissions, tCO2e (Example) | 384,000 | 425,600 | 454,400 | n/a | n/a | n/a | Utilities reallocation (ACT-001) |
| 2 Carbon footprint (Example) | 118 | 131 | 140 | n/a | n/a | n/a | Same; coverage stable at 91% |
| 4 Fossil fuel exposure (Example) | 3.5% | 4.4% | 5.1% | n/a | n/a | n/a | Thermal coal exclusion (ACT-003) |
| 13 Board gender diversity (Example) | 36% | 33% | 31% | n/a | n/a | n/a | Voting policy (ACT-005) and issuer changes |
| [Indicator] | [Value] | [Value] | [Value] | [Value] | [Value] | [Value] | [Driver] |
Mark restated figures and give the reason. Where the firm started publishing recently, "n/a" means no earlier statement exists, which is expected and should be stated in a footnote.
10. Data governance and controls
| Control ID | Control | Frequency | Evidence | Owner |
|---|---|---|---|---|
| DQ-001 (Example) | Reconcile in-scope holdings and values at each quarter end to the portfolio accounting system | Quarterly | Reconciliation report with breaks resolved | [@operations] |
| DQ-002 (Example) | Match each holding to the issuer identifier used by data vendors (LEI, ISIN); review unmatched items | Quarterly | Match rate report | [@data-office] |
| DQ-003 (Example) | Flag reported versus estimated values per indicator and compute coverage | Quarterly | Coverage table | [@sustainability-analyst] |
| DQ-004 (Example) | Recalculate indicators 1 to 4 independently for a sample of portfolios | Annually | Recalculation workpaper | [@risk] |
| DQ-005 (Example) | Review year-on-year movements above 10% and document drivers | Annually | Variance analysis | [@head-of-sustainability] |
| DQ-006 (Example) | Check that published figures equal the approved workpaper | At publication | Sign-off record | [@compliance] |
| DQ-007 (Example) | Version and archive the vendor data snapshot used for each quarter end | Quarterly | Snapshot file and hash | [@data-office] |
Apply the firm's Data Quality Standard (data/data-quality-standard) for completeness, accuracy and timeliness
thresholds, and record data issues and remediation in a log that the next year's preparer can read.
10.1 Traceability matrix
| Requirement | Statement section | Calculation workpaper | Control | Evidence owner |
|---|---|---|---|---|
| SFDR Article 4(2)(a), RTS Article 7 | 6 | n/a | DQ-006 | [@compliance] |
| SFDR Article 4(2)(b), RTS Article 6 | 4 | [WP-PAI-01] | DQ-001 to DQ-005 | [@sustainability-analyst] |
| SFDR Article 4(2)(c), RTS Article 8 | 7 | [WP-ENG-01] | DQ-006 | [@stewardship-lead] |
| SFDR Article 4(2)(d), RTS Article 9 | 8 | [WP-ALIGN-01] | DQ-006 | [@sustainability-analyst] |
| RTS Article 5 | 3 | n/a | DQ-006 | [@head-of-sustainability] |
| RTS Article 6(3) quarterly averaging | 5.2 | [WP-PAI-01] | DQ-001, DQ-007 | [@data-office] |
| RTS Article 10 | 9 | [WP-PAI-HIST] | DQ-005 | [@sustainability-analyst] |
11. Link to product-level disclosures
Where the firm applies Article 4(1)(a), 4(3) or 4(4), SFDR Article 7 requires each financial product's pre-contractual disclosures to explain whether and how the product considers principal adverse impacts (or why not), and the periodic reports to show how they were considered. Keep the entity statement and the product documents consistent.
| Product or mandate | SFDR classification | Considers PAI at product level | Indicators considered | Consistent with entity priorities |
|---|---|---|---|---|
| Kestrel Bay Euro Equity Mandate (Example, fictional) | Article 8 | Yes | 1 to 4, 10, 14 | Yes |
| Kestrel Bay Global Bond Mandate (Example, fictional) | Article 6 | No, reason stated | n/a | Reason consistent with section 6 |
| [Product] | [Article 6 / 8 / 9] | [Yes / No] | [Indicators] | [Yes / No, action] |
PAI consideration is also one of the forms of sustainability preference that a client may express in the MiFID II
suitability assessment. Make sure the product data given to advisers and portfolio managers matches what the entity
statement says; see the Client Risk Profile (finance/client-risk-profile) and the MiFID Suitability Report
(compliance/mifid-suitability-report). The firm's broader ESG integration and exclusion approach belongs in the
Responsible Investment Policy (finance/responsible-investment-policy).
12. Production workflow and calendar
| Milestone | Target date | Owner | Done |
|---|---|---|---|
| Holdings snapshots taken and reconciled | Within 10 business days of each quarter end | [@operations] | [ ] |
| Vendor data cut-off for reference year | YYYY-03-31 | [@data-office] | [ ] |
| Indicator calculation complete | YYYY-04-15 | [@sustainability-analyst] | [ ] |
| Explanations, actions and targets drafted | YYYY-04-30 | [@head-of-sustainability] | [ ] |
| Summary translations complete | YYYY-05-20 | [@translation-owner] | [ ] |
| Compliance and data sign-off | YYYY-06-05 | [@compliance], [@data-office] | [ ] |
| Governing body approval | YYYY-06-15 | [@management-board] | [ ] |
| Publication | No later than YYYY-06-30 | [@web-owner] | [ ] |
13. Alternative: no consideration statement
Website section title: "No consideration of adverse impacts of investment decisions on sustainability factors".
| Element (RTS Article 12(2)) | Content |
|---|---|
| Prominent statement that the firm does not consider any adverse impacts of its investment decisions on sustainability factors | [Statement] |
| Reasons for not considering them | [Size, nature of strategies, data availability, cost relative to scale, with specifics] |
| Whether the firm intends to consider them by reference to the Table 1 indicators, and if so when | [Intention and target date, or "no current intention"] |
Review this decision annually, and immediately if the average employee count approaches 500 or the firm becomes the parent of a large group.
14. Regulatory change watch
| Item | Status as of 2026-10 | Effect on this statement | Checked on |
|---|---|---|---|
| SFDR 2.0: Commission proposal amending Regulation (EU) 2019/2088, COM(2025) 841, procedure 2025/0361(COD), published 20 November 2025 | Not law as of 2026-10: the European Parliament and the Council have adopted their negotiating positions and trilogue negotiations are under way; check the current status in the Legislative Observatory (procedure 2025/0361(COD)). The proposal would remove the entity-level PAI statement and repeal Delegated Regulation (EU) 2022/1288 with new product rules | None until adopted and applicable. Keep producing the statement each year until the amending act applies. Plan for transition dates in the final text | YYYY-MM-DD |
| Joint ESAs final report on the review of the PAI and product disclosure RTS (December 2023) | Draft amendments submitted to the Commission; check whether adopted. As of this template's date they have not been adopted into the Delegated Regulation | Possible new mandatory indicators and formula changes if adopted | YYYY-MM-DD |
| Commission Delegated Regulation (EU) 2023/363 of 31 October 2022 | Adopted; amends and corrects Delegated Regulation (EU) 2022/1288, mainly the pre-contractual and periodic product templates for investments in environmentally sustainable activities, including fossil gas and nuclear | Work from the consolidated text of Delegated Regulation (EU) 2022/1288, which includes these changes | YYYY-MM-DD |
| Joint ESAs questions and answers on SFDR and the Delegated Regulation | Updated periodically | Calculation conventions (denominator, coverage, look-through) | YYYY-MM-DD |
| CSRD and ESRS reporting by investee companies | Phased application; simplification changes agreed in 2025 to 2026; check the current scope | Availability of reported data for indicators 1 to 14 | YYYY-MM-DD |
15. Glossary
| Term | Meaning in this statement |
|---|---|
| Principal adverse impacts (PAI) | Negative effects of investment decisions on sustainability factors that the firm judges most significant, measured through the Annex I indicators and others it adds |
| Sustainability factors | Environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters (SFDR Article 2(24)) |
| Financial market participant | An entity listed in SFDR Article 2(1), such as a portfolio manager, AIFM, UCITS management company or insurer offering insurance-based investment products |
| SFDR RTS | Commission Delegated Regulation (EU) 2022/1288, the regulatory technical standards that set the content and template of the statement |
| EVIC | Enterprise value including cash: market capitalisation of ordinary and preferred shares plus book value of total debt and non-controlling interests, without deducting cash, at fiscal year end |
| Attributed emissions | The share of an investee's emissions allocated to the firm in proportion to its investment relative to the investee's EVIC |
| Carbon footprint | Attributed emissions divided by the current value of all investments, in tCO2e per EUR million invested |
| GHG intensity | Portfolio-weighted average of investee emissions per EUR million of revenue |
| Coverage | Share of the relevant investments, by value, with reported or estimated data for an indicator |
| Scope 1, 2, 3 | Direct emissions, indirect emissions from purchased energy, and other indirect value chain emissions |
| tCO2e | Tonnes of carbon dioxide equivalent |
| Article 8 and Article 9 products | Products that promote environmental or social characteristics (Article 8) or have sustainable investment as their objective (Article 9) |
16. References
| Reference | Version or date | Used for |
|---|---|---|
| Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR) | 27 November 2019, OJ L 317, 9.12.2019; applies from 10 March 2021; check the consolidated text | Article 2 definitions, Article 4 entity-level obligations, Article 7 product link |
| Commission Delegated Regulation (EU) 2022/1288 (SFDR RTS) | 6 April 2022, OJ L 196, 25.7.2022; applies from 1 January 2023; amended by Delegated Regulation (EU) 2023/363 | Articles 2, 4 to 13, 23 and Annex I Tables 1 to 3 |
| Directive 2007/36/EC (Shareholder Rights Directive), Article 3g, as amended by Directive (EU) 2017/828 | Check the consolidated text | Engagement policy summaries |
| Directive 2013/34/EU, Article 3(7) | Check the consolidated text | Definition of large group for Article 4(4) |
| Proposal COM(2025) 841, procedure 2025/0361(COD) (SFDR 2.0) | Commission proposal of 20 November 2025; is a proposal and not law as of 2026-10: the European Parliament and the Council have adopted their negotiating positions and trilogue negotiations are under way; check the current status | Regulatory change watch only |
| Joint Committee of the ESAs, questions and answers on SFDR and Delegated Regulation (EU) 2022/1288 | Current version on the ESAs websites | Calculation conventions; not endorsed by the ESAs |
| OECD Guidelines for Multinational Enterprises on Responsible Business Conduct; UN Global Compact; UN Guiding Principles on Business and Human Rights; Principles for Responsible Investment | Names only | Section 8 references |
Standard and licence note
Based on Regulation (EU) 2019/2088 (SFDR) and Commission Delegated Regulation (EU) 2022/1288, Articles 4 to 13 and Annex I, as published in the Official Journal of the European Union and available on EUR-Lex (reuse authorised with acknowledgement of the source under Commission Decision 2011/833/EU). Article and table numbers are cited and the requirements are summarised in original wording; indicator names follow the Annex I table so that statements stay comparable, and no other legal text is reproduced. SFDR 2.0 (COM(2025) 841) is described as a proposal only. International codes and standards are named without reproducing their content, and their mention implies no endorsement by their owners. All examples, including Kestrel Bay Capital Europe and the companies in the worked example, are fictional. Check the current consolidated texts on EUR-Lex, adopted amendments and the current ESAs questions and answers before use. This is a document format, not legal, investment or regulatory advice. Template licence: MIT.
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