ICMA publishes commentary and recommendations for the SFDR review
4 February 2026 In this position paper, ICMA presents its commentary and recommendations on the Sustainable Finance Disclosure Regulation (SFDR) 2.0 as feedback for the upcoming EU co-legislation process.
In short, ICMA welcomes the direction of travel of the SFDR 2.0 which takes into account industry feedback for a simplified disclosure regime and a clearer ESG fund categorisation system. As per the Commission’s proposal, the latter would consist of “Transition”, “ESG Basics”, and “Sustainable” categories.
Otherwise, ICMA’s recommendations for further improvement and clarification focus on the following:
For the general aspects of the SFDR
- Extension of exclusions to legacy coal exposure
- Treatment of non use-of-proceeds (UoP) instruments of public entitie
- Voluntary disclosure for all relevant funds
- Effective implementation
For the treatment of UoP bonds and funds
- Explicit recognition of credible market standards and other credible tools
- Application of category exclusions to UoP bonds and funds.



