GRESB SFDR Reporting Solution FAQ

SFDR applies to Financial Market Participants (FMPs) that offer financial products domiciled in the EU. According to Article 2 of SFDR, FMP means:

(a) an insurance undertaking which makes available an insurance-based investment product (IBIP);

(b) an investment firm which provides portfolio management;

(c) an institution for occupational retirement provision (IORP);

(d) a manufacturer of a pension product;

(e) an alternative investment fund manager (AIFM);

(f) a pan-European personal pension product (PEPP) provider;

(g) a manager of a qualifying venture capital fund registered in accordance with Article 14 of Regulation (EU) No 345/2013;

(h) a manager of a qualifying social entrepreneurship fund registered in accordance with Article 15 of Regulation (EU) No 346/2013;

(i) a management company of an undertaking for collective investment in transferable securities (UCITS management company); or

(j) a credit institution which provides portfolio management;

In case your organization fall under any of the definitions above, SFDR will apply to you.

As per Articles 6 and 7 of the current SFDR Delegated Regulation, and as facilitated by the corresponding Annex contained in that same document, FMPs are required to disclose the principal adverse impacts of their investment decisions on sustainability factors.

As per Article 6 of the current SFDR Delegated Regulation, Financial Market Participants “shall complete all the fields that relate to the indicators related to principal adverse impacts of their investment decisions on sustainability factors” in Table 1 of Annex 1. Thus, FMPs are expected to disclose on all 14 indicators applicable to their investments in investee companies, and/or all indicators that are applicable to their investments in real estate assets. Annex 1 also provides two additional tables with voluntary indicators from which an FMP needs to pick one of each. 

In case FMPs do not take into account the PAIs (i.e. Article 6 products), they don’t have to disclose a PAI Statement under Article 7. 

The EU has not provided guidelines on the quality of estimates. However, it has stated that estimations will be allowed for disclosure purposes, at least in the near term (Please see the ESAs latest consultation report published in December 2023). 

Where needed, GRESB will use estimates based on our dataset that consists of over 117,000 assets to fill gaps in data coverage and, consequently, provide members with an accurate picture of their environmental footprint. GRESB’s extensive database allows us to find comparator assets at the country- and property-type levels. This is rather unique to GRESB, and it means that from the very beginning, your SFDR reporting statement will be more accurate, even if you need to rely on some estimated data. 
Note that data quality aspects are likely to come into force with CSRD (Corporate Sustainability Reporting Directive) , which could potentially influence which data points are acceptable. 

The GRESB SFDR Reporting Solution is available as a standalone assessment to anyone that wants to use it to meet their disclosure requirements, and it is primarily focused on helping fund managers collect and ultimately disclose their PAIs at the financial product level. Should they wish to, fund managers will be able to share their data with investors in 2024 . 
 
GRESB is open to feedback as to investor needs when it comes to SFDR. 

For Infrastructure: assets and investments are considered to fall under the indicators applicable to ‘Investments in investee companies’.

For Real Estate: the SFDR Solution targets the PAI indicators that are directly applicable to investments in real estate assets only. These are indicators 17,18 from Table 1, Indicators 18-22 of Table 2, as well as the ability to report on any of the non-mandatory indicators present in Table 3. 

Given the ever-changing regulatory environment, GRESB will remain vigilant and update the PAIs in accordance with the latest regulation. Currently the GRESB SFDR Solution reflects the PAIs from the SFDR Delegated Regulation of 6 April 2022. GRESB is closely monitoring the latest SFDR updates proposed by the ESA’s in their Final Report of December 2023 and will act accordingly once an application date is finalized by the European Commission. 

GRESB’s solution for PAIs will be the same for Article 6, 8, and 9 funds and the same assessment applies regardless of the funds designation.

For SFDR reporting, the GRESB Assessment already captures some of the quantitative environmental data, such as GHG Emissions, Energy consumption, Water consumption, and Waste. Other qualitative metrics for SFDR will require new data to be collected.

For Real Estate – focusing on reporting efficiency and with the aim to reduce reporting burden, the same Asset Spreadsheet used to report quantitative metrics for SFDR will be reused for the main GRESB Real Estate Assessment purposes.

Note that different validation rules will apply.

Members that report to both SFDR and the GRESB Real Estate Assessment will only have to submit asset-level data once. The GRESB Asset Spreadsheet will be used for both the SFDR and the main assessment, and data uploaded in the Asset Portal will be used to populate both assessments.

No, although reporting and gathering data on the PAIs via GRESB can indirectly help with that transition by providing our members with a more accurate picture of their environmental, social and governance indicators and metrics.

For the time being, GRESB’s SFDR Reporting Solution will not validate the data provided by participants, as SFDR reporting is not currently subject to validation. GRESB has created the platform so data can be validated – similar to the GRESB Assessment – if and when it becomes required by regulators.

Yes, the 2024 SFDR Assessment also facilitates the year-on-year comparisons required by the SFDR in 2024, thereby allowing both 2022 and 2023 data to be input for the purposes of this comparison.  

You can find a sample report and more information on our product page: gresb.com/SFDR

The GRESB SFDR Assessments are independent of the GRESB Real Estate and Infrastructure Assessments to enable year-round reporting.

The 2024 SFDR Assessment reporting will run from Q1 through Q4, 2024, and will facilitate reporting for the ‘2023 reference period’. As reports are not dependent on human validation, scoring, or benchmarking, they can be generated as many times as necessary by the participant member.

As a reminder, the GRESB Assessment reporting period opens April 1 and closes July 1 and does not include all necessary information on mandatory and optional Principle Adverse Impacts indicators, whereas the GRESB SFDR Assessment will include these indicators.

We have created a mapping document where data points that match between the GRESB and SFDR Assessments are identified so participant members can easily transfer information from one assessment to the other. This can be found in the appendix of the Infrastructure Asset SFDR Reference Guide.

We are also working on an automated data transfer functionality for Infrastructure Assets, where information from Principal Adverse Impact Statements can be transferred to the GRESB Assessment and the other way around.

As of November 2023 non-listed investors can request access to managers’ SFDR report and data. 

As it is the case for the GRESB assessments, as a participating entity, you need to give your explicit consent for GRESB Investor Members, or Fund Managers, to see your data and SFDR Reports. 

By engaging with managers on SFDR compliance, investors can future-proof their portfolio and receive additional timely insights to inform their investment decisions. 

In addition to streamlining access to these insights, this new process also enables investors to express their interest in viewing the reports to managers who may not have purchased the product(s) yet. 

Express of interest requests can be accepted only after the purchase of the product. You can always decline an Express of interest request. 

For more information, please have a look at the investor access rights page here. 

The Real Estate Assessment currently allows investors to access asset-level data (dependent on participants permission) through the Asset Analytics. This will not directly apply to SFDR, as we will only provide aggregated performance metrics and fund-level indicators in the Data Exporter. 
 
However, please note that the same asset-level data used for SFDR purposes will be reused in the GRESB Real Estate Assessment. Therefore, where a participant reports both to SFDR and the GRESB Real Estate Assessment, investors will have access to this data. 

Yes, the Data Exporter provides access to data points in both the GRESB Assessments and SFDR Assessments. The exported datasets are available in .csv and .xlsx format for custom analysis and modelling. For more information on the Data Exporter Tool please refer to this link.