As of this week, the EU Sustainable Finance Disclosure Regulation (SFDR) has come into effect, introducing new obligations and standards for all firms selling financial products within or into the EU.



What is the SFDR timeline?

SFDR Timeline_Turnkey


What are the requirements?

Official SFDR reporting commences at the beginning of 2022, when the final Regulatory Technical Standards (RTS) enters into force. In the interim, the draft RTS document outlines a set of indicators (PAIs) that qualifying firms will need to report on, as well as rules on disclosure on specific characteristics depending on the nature of the fund manager.

In 2021 mandatory disclosure of PAIs applies to big Fund Managers, while other in-scope firms need to disclose most of the information on a “comply or explain” basis. Starting from January 2022, SFDR reporting will become mandatory to all qualifying firms.

What is the key challenge?

Critical to the overall transparency and robustness of the reporting process will be the collection and aggregation of data. Private Equity firms will need to collect data from all portfolio companies and map the aggregated fund level position into the relevant SFDR categories.

The 2021 interim and 2022 full reporting processes are likely to be very manually intensive for GPs and potentially very intrusive for portfolio companies without upfront investment in tools designed to automate and streamline the process.

How can Turnkey help?

Turnkey’s Smart Survey solution, supported by our dedicated ESG in-house experts makes data collection, analysis and reporting against SFDR requirements easy, reliable and transparent. The key characteristics of our solution are:

  • Seamlessly mirrors the SFDR disclosure template, including behind the scenes technical content updates as required

  • Digitalises SFDR data collection centrally, gathering data from portfolio companies in a non-intrusive and efficient manner

  • Tracks SFDR performance year-on-year

  • Assigns weighted scoring to apply intelligent analysis to portfolio company responses in order to create a leaders/laggards table

  • Identifies areas of fund/portfolio company risks that require active mitigation

  • A cost-effective tool that can be easily re-used by the GP for a range of purposes

We work with a selection of experienced legal firms should you wish to combine robust data capture and reporting through our platform with comprehensive legal wrap-around advice supporting your SFDR submission.



SFDR solution from the leader in sustainability software

SFDR Dashboard_Turnkey

What else can the Smart Surveys do?

Our private equity clients utilise the Smart Surveys platform for multiple applications across their portfolios given its ease of configuration and operation. Other applications have included capturing social metrics/KPIs, compliance with other reporting frameworks and identifying risk across business-critical operations (including cyber security and data protection, corporate legal risk evaluation, travel policies and safe movements).

Please feel free to contact Turnkey team for more information.


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