Integration of sustainability concepts into AIFMD, UCITS and MIFID regimes
On 2 August 2021, the final level 2 measures were published by the European Commission focusing on the integration of sustainability - as defined in SFDR - into AIFMD, UCITS, MiFID products and MiFID suitability.
EU AIFMs, UCITS management companies, and MiFID investment firms which are currently subject to any or all the AIFMD, UCITS or MiFID regimes will be affected by these changes. The changes to the MiFID regime will also affect fund managers who perform MiFID services such as portfolio management and investment advice.
Updates of existing rules to take account of sustainability:
• Organisation (AIFMD, UCITS & MiFID)
• Conflicts of interest (AIFMD, UCITS & MiFID)
• Due diligence when making investment decisions (AIFMD & UCITS)
• Suitability assessment (MiFID)
• Product governance (MiFID)
These changes are applicable from 1 August 2022 for AIFMD and UCITS. They are applicable from 2 August 2022 for MiFID “Organisational Requirements” and from 22 November 2022 for MiFID “Product Governance”.