SFDR readiness · Sustainability disclosures in financial services
Your SFDR set-up measured, its gaps documented, its action plan costed.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
SFDR readiness · Sustainability disclosures in financial services
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2019/2088 (SFDR) and delegated regulation (EU) 2022/1288 (RTS) assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism, a level, a level above, and the action linking the two, is what turns a finding into a trajectory.
Is the coverage and quality of data used for adverse impact indicators under control?
- N1
No coverage tracking. Indicators are calculated with the data available, with no measure of what is missing.
- N2
The coverage rate is calculated during annual production, but there is no written rule on how missing data is treated.
- N3
A documented method defines sources, coverage thresholds and the use of estimates. It is applied across all published indicators.
- N4
Coverage is monitored more often than annually, gaps are subject to a remediation plan with data providers, and estimates are validated by a named body.
- N5
The method is reviewed each year in light of regulatory changes and issuer data availability, with a documented history of revisions and their effect on published indicators.
Action to move from L2 to L3
Draft the missing data treatment procedure (sources in priority order, minimum coverage threshold, permitted estimation method), have it approved by the sustainability committee and apply it from the next indicator calculation cycle.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurementon SFDR.
What this framework covers
Regulation (EU) 2019/2088, known as SFDR, has applied since 10 March 2021 to financial market participants and financial advisers. It imposes two layers of disclosure. At entity level: policies on the integration of sustainability risks, consideration of principal adverse impacts, and consistency of remuneration policies. At product level: pre-contractual information, periodic information and website information, depending on whether the product falls under article 6, article 8 or article 9. Delegated regulation (EU) 2022/1288 sets out the templates and indicators to be completed.
The difficulty is not understanding the text, it is making the information production chain hold together. Principal adverse impact indicators depend on issuer data that is often incomplete: what coverage rule, what estimation method, and who validates it? Product classification involves the sales function as much as the risk function: on what evidence does a product falling under article 8 retain that qualification from one year to the next? Finally, periodic information must be consistent with the pre-contractual information published two years earlier, which requires a level of traceability few set-ups actually have.
One point of context is worth clarifying. SFDR is not a label and does not create categories of sustainable products: articles 8 and 9 are disclosure regimes, not quality certifications. Revision work under way at European level, notably the proposal to simplify sustainability reporting, may change the categories and their relationship with CSRD and the taxonomy. Organisations that built their set-up as a one-off documentary exercise will have to redo it. Those that built it as a tooled data process will adapt it.
A compliance check answers yes or no: the document exists, the indicator is completed, the template is followed. A maturity assessment asks a different question: what level of control does each link in the chain have, from data collection to validation of published content, and what specific action moves it up to the next level. It is this lens that lets you decide between fixing an indicator and industrialising its production.
In Datamensio, the SFDR framework is ready to use and adaptable. The AI adjusts the themes, questions and levels to your type of firm, asset manager, insurer, distributor or adviser, or builds a variant from your own policies and pre-contractual documents.
Reference standard: Regulation (EU) 2019/2088 (SFDR) and delegated regulation (EU) 2022/1288 (RTS)
The themes assessed
Governance of the sustainability set-up
Roles and responsibilities between compliance, risk, ESG and portfolio management, disclosure sign-off body, resource allocation, alignment with product governance.
Integration of sustainability risks
Policies published on the website, effective consideration in the investment or advice process, formalisation of criteria, periodic review.
Principal adverse impacts (PAI)
Entity-level statement, mandatory and additional indicators selected, coverage rate, estimation methods, mitigation and engagement actions.
Product classification
Article 6, 8 or 9 qualification, decision criteria, evidence retained, reclassification procedure, consistency with marketing documentation.
Pre-contractual disclosure
Use of delegated regulation templates, description of environmental or social characteristics, share of sustainable investments, taxonomy alignment, measurement indicators.
Periodic disclosure
Report on the extent to which characteristics were met, comparison with prior periods, consistency with pre-contractual information, production schedule.
Data chain and quality
Data sources and providers, completeness and consistency checks, treatment of missing data, calculation traceability, retention of audit trails.
Remuneration policies and due diligence
Consistency of remuneration policies with integration of sustainability risks, due diligence, shareholder engagement procedures.
Preventing misleading claims
Control of marketing materials and product naming, consistency between promise and portfolio, review process before publication.
Alignment with CSRD, taxonomy and steering
Reuse of data from issuer sustainability reporting, common indicators, regulatory monitoring, plan to adapt to changes in the framework.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does the assessment replace an SFDR compliance check?
No. A compliance check verifies that the required disclosures exist and follow the regulatory templates. The assessment gauges the maturity of each link in the set-up and points to the trajectory for improvement. It prepares for the check, it does not replace it, and it issues no certificate.
Does SFDR carry a certification?
No. SFDR is a transparency regulation, with no certifying body. Articles 8 and 9 are disclosure regimes, not labels. Datamensio measures the maturity of your set-up and prepares you for supervisory or audit reviews.
How long does the assessment take?
The short version takes 20 to 30 minutes for a compliance or sustainability officer to complete. The full version, run collaboratively, generally takes one to two weeks, most of the time spent gathering input from portfolio management, data and legal teams.
Can the framework be adapted to our type of firm?
Yes. Questions, levels and themes can be edited, and you can add your own. The AI generates a variant suited to an asset manager, insurer, distributor or financial adviser, based on your policies and pre-contractual documents.
How does this assessment fit with CSRD and the taxonomy?
The three frameworks share data and indicators. A documented SFDR assessment identifies what is reusable, particularly across the issuer data chain. Cross-framework roadmaps consolidate several assessments to avoid duplicating actions.
Can several entities or product ranges be compared?
Yes. The same framework applies to each business unit or product range, with a score per theme. The benchmark compares entities against each other and each against its own past assessments, which helps target methodological gaps.
What does the assessment actually produce?
A score per theme, a target, and the gap between the two that generates the action plan. The AI groups these actions into a prioritised roadmap, and the service catalogue matches a solution to each action with its cost, timeline and expected impact on the score.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.