Shauna joined the BD team at Integrum ESG in 2021, having previously worked in similar roles within Fintech companies. She holds a BA in English and New Media Studies from the University of Limerick, Ireland.
Integrum ESG and Investment Solutions Consultant Ltd (ISC) co-hosted a private breakfast session on SFDR 2.0 preparedness, bringing together senior representatives from asset managers like BNY Investments, Royal London Asset Management, Ninety One, Vanguard, M&G Investments and more.
The conversation covered fund reclassification, data readiness, exclusion compliance and the growing complexity of running strategies across both the EU and UK regulatory regimes. What follows is a summary of the key themes raised.
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Mapping existing Article 6, 8 and 9 funds to the new five-category framework (a summary of which can be read here) is the most pressing near-term task for asset managers, and the consensus across the room was that it is proving more involved than initial scoping suggested, particularly across larger and more diverse fund ranges.
The new structure introduces Article 6a for non-categorised funds, Article 7 for transition strategies, Article 8 for systematic ESG integration, Article 9 for funds pursuing a sustainability objective and Article 9a for fund-of-funds investing in categorised products. A 70% minimum asset alignment requirement applies across Articles 7, 8, 9 and 9a.
A fund currently at Article 8 or 9 may not qualify for its nearest equivalent without changes to exclusions, portfolio construction or underlying data.
Attendees noted that the mapping exercise is surfacing issues not visible under the current framework, and that resolving them requires coordination across investment, product and compliance teams rather than sitting with one function alone.
SFDR 2.0 exclusion requirements differ materially across the new categories, and managers in the room were direct that this is a portfolio construction challenge as much as a compliance one.
Articles 7, 8, 9 and 9a must all apply Climate Benchmark exclusions, covering coal mining, coal power without a credible phase-out plan, oil and gas expansion, controversial weapons and repeated breaches of global norms. Articles 7 and 9 go further, with stricter fossil-related rules limiting exposure to companies pursuing new fossil projects.
Exclusion compliance cannot be addressed through disclosure language alone. It requires a direct assessment of what is held in the portfolio and whether current investment processes are compatible with the intended category.
For some funds, that means portfolio changes. Managers in the room were running that analysis now rather than waiting for final technical standards.
Data availability was raised consistently across the session as the most significant operational challenge firms are facing.
The move from the current RTS reporting templates to category-specific indicators requires a level of granularity that many existing data arrangements do not yet support.
The expected disclosure format, a table-driven template covering sustainability objectives, asset allocation breakdowns, taxonomy alignment percentages and Key Sustainability Indicators, demands reliable and auditable inputs at the fund level.
Many firms noted they are already in active conversations with their data providers as a result, and that the process of identifying gaps has been instructive in itself, surfacing mismatches between what current providers offer and what the new indicator requirements will actually demand.
For teams beginning that assessment, Funds Intelligence provides fund-level ESG and climate analytics with data updated within 10 days of any issuer disclosure.
The shift in Principal Adverse Indicator treatment was broadly welcomed.
The removal of a mandatory entity-level PAI requirement, combined with more flexibility for funds to define their own approach, was seen as a practical improvement on the current framework.
The flexibility carries its own challenge, however. Funds in Articles 7 and 9 still need to demonstrate active consideration of adverse impacts, and the retirement of Article 2.17 as a mandatory concept means managers need to be explicit about what they are substituting in its place and why.
Those in the room are treating this as an opportunity to build more coherent and defensible methodologies rather than simply meeting a minimum threshold.
For managers running strategies across both the EU and UK, the session surfaced a consistent concern: the structural differences between SFDR 2.0 and the UK Sustainability Disclosure Requirements framework are not yet fully reflected in operational planning.
The UK's four labels, Sustainable Focus, Impact, Improvers and Mixed Goals, do not map cleanly onto the EU categories. The non-prescriptive nature of the UK regime means managers are, in effect, building two parallel frameworks. With fewer than 130 funds currently labelled under UK SDR and over half sitting in Sustainable Focus, the market is still settling. Attendees managing dual-jurisdiction ranges were clear that this cannot be treated as a future problem.
For managers navigating both regimes, Regulatory Intelligence unifies SFDR, UK SDR and TCFD compliance within a single audit-ready platform.
For a broader view of how the EU and UK regulatory regimes are diverging, see our Regulatory Landscape in 2026 briefing.
The firms we have mentioned in this article are not at the starting line.
Many have already begun fund mapping exercises, are reviewing exclusion and benchmark policies and are in active conversations with their data providers.
A point that came through clearly was the importance of early engagement across product, compliance and investment teams - this is not work that can sit with one function, and the firms making the most progress are the ones that have already broken down those internal silos.
The collective view was that the 2028 implementation date creates a false sense of distance, given the volume of product, data and governance work that needs to happen first.
Preparation is not a compliance function alone. It cuts across investment, product, distribution and operations, and the asset managers moving fastest are treating it accordingly.
If you want to understand where your funds sit under the new SFDR 2.0 categories, our team can run the assessment and walk you through the results.
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