10 March 2021 is the first significant compliance deadline for funds and fund management companies under the EU’s Action Plan on Sustainable Finance (the Action Plan).  This legislative deadline will impact all UCITS, AIFs, UCITS management companies and AIFMs.  The Action Plan comprises an extensive, detailed and ambitious set of measures which demand significant lead-time to ensure timely compliance.  Cognisant of this, our Asset Management & Investment Funds team has undertaken a deep-dive analysis of the Action Plan to produce a practical Compliance Action Plan for use by our client funds and fund management companies in planning for and demonstrating compliance with these new rules. Our Compliance Action Plan cuts through the volume of new legislation to helpfully summarise all pertinent aspects of the new regime in an approachable, manageable way and allows for ready identification of the obligations and attendant deadlines relevant to all types of funds (clearly grouping those requirements which are specific to ‘light green’, ‘dark green’ and other funds for ease of application). To this end the Compliance Action Plan features:

• a compliance Decision Tree which allows fund management companies, as a first step, to readily identify the extent to which they are obliged or may otherwise choose/wish to comply with the EU’s sustainable finance rules;
• manager and product Compliance Checklists for fund management companies, ‘light green’ and ‘dark green’ funds including relevant compliance deadlines, to assist with planning for and demonstrating compliance; and
• detailed Requirements Matrices (corresponding to the Compliance Checklists) which tabulate all legislative requirements published to date, including the ESAs’ draft Level 2 Disclosures Regulation measures and UCITS and AIFMD delegated acts.

Please click on the image below to download the Compliance Action Plan.