SFDR UCI periodic data collection

1. Purpose and Scope

The guide offers practical and technical instructions for the collection of annual sustainability-related data under the SFDR (Sustainable Finance Disclosure Regulation) from UCITS, AIFs, and IORPs disclosing under Articles 8 or 9. It outlines the data fields required and the submission procedures.

2. Who Must Submit Data?

Financial market participants (FMPs) within the European Economic Area must participate in the data collection if they manage UCITS, AIFs, or IORPs domiciled in Luxembourg and disclosing under SFDR Article 8 or 9. This includes various categories such as management companies, investment companies, and IORPs.

3. Reporting Timing and Deadlines

• First mandate: For annual reports published between 1 January and 31 December 2023, data must be submitted by 31 January 2024.

• Ongoing schedule: For reports from 1 January 2024 onwards, data must be submitted within one month of the legal publication deadline of the annual report:

  • UCITS: within 5 months after financial year-end

  • AIFs & IORPs: within 7 months after financial year-end

4. Submission Channels

Two primary submission methods are provided:

1. S3 system (API):

   • Reports must be in JSON, zipped, and uploaded to the “submission” folder.

   • ZIP file naming conventions must follow a strict pattern, including reporting entity code, type (“PERIO”), exercise end date, and UUID.

   • CSSF returns feedback as a JSON file in the “feedback” folder. It includes status (ACCEPTED, PARTIALLY_ACCEPTED, REJECTED) and detailed error messages.

2. eDesk online form:

   • Authenticated users can create and submit reports through CSSF’s web platform.

   • Offers user-friendly features: report creation, data entry, PDF export, dashboard for tracking, and delegation management.

   • It also allows retrieval and modification of previously submitted data.

5. Data Requirements

The reporting template depends on whether a sub-fund discloses under Article 8 or Article 9. Key data fields include:

• Sub-fund identifiers, liquidation status/date

• Indicators of sustainable investments and their proportions

• Whether investments align with the EU Taxonomy (including breakdown by fossil gas, nuclear, transitional/enabling activities)

• Environmental/social characteristics being promoted

• Governance considerations

• Reference benchmark designation and performance comparison

Full detail of required data items is provided in Annexes I (Article 8) and II (Article 9), with Annex III covering top investments and Annex IV listing codes for closed questions.

6. Technical Support & Testing

• A dedicated test environment is available on request for end-to-end testing.

• Entities may request access by emailing the CSSF and specifying external IP ranges.

• For support with reporting or technical issues, contact: ucisfdr@cssf.lu