The SFDR II Proposal: An Overview

A post by Dr. Arnaud Van Caenegem

The European Commission published its proposal for amending the Sustainable Finance Disclosure Regulation (SFDR) on 20 November 2025, accompanied by a Q&A. The proposal also explicitly amends the PRIIPS Regulation and is understood to implicitly “moot” certain provisions of the Taxonomy Regulation that reference the SFDR.

The SFDR has been discussed in a previous post as a disclosure regulation, adopted with the objective to harmonize the provision of sustainability-related information in individual and collective investment activities by financial market participants, financial advisers and financial products. The Commission proposal introduces a second objective: the creation of a harmonized categorization of sustainability-related products.

This post covers the three key proposed changes: a substantial reduction of the obligations for financial market participants, a limitation of the scope to “collective investment”, and a shift from a disclosure to a categorization framework.

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