SFDR’s Early-Life Crisis Presents an Opportunity to

SFDR’s Early-Life Crisis Presents an Opportunity to Level the Playing Field 6 The Regulatory Background Despite phased implementation, the pace and breadth of regulatory transformation in European financial markets have presented challenges, not only to financial market participants (FMPs) and advisers (FAs), but also to the majority of the real economy with a presence in the European Union (EU). [...] SFDR’s Early-Life Crisis Presents an Opportunity to Level the Playing Field 9 recognition, until the launch of the most recent consultation, little indication had been given that the Commission was ready to meaningfully review the fundamentals of SFDR. [...] This would be the largest departure from the existing framework and the impact of such a conversion will form the basis of much discourse between now and the December deadline. [...] Given the interdependency of regulatory directives, to second-guess the existence of SFDR might on the face of things call into question the validity of an entire regulatory approach—one that has been adopted at considerable expense, and not only by financial market participants. [...] What this latest consultation means for others, such as the joint ESAs consultation on the regulatory technical standards for SFDR, remains to be seen, and it would be easy to simply pay lip service to earlier sections of the current consultation that focus on the existing requirements and interactions of SFDR.