- in South America
- in South America
Key dates
Highlights during the period
In this latest edition of the Walkers ESG newsletter, we identify a number of key highlights from European legislative and regulatory developments and advances in the global sustainable finance framework more broadly.
SFDR-related Developments
On 20 November 2025, the Commission released the legislative text of a proposed targeted set of amendments to the SFDR framework ("SFDR 2.0"). If implemented, SFDR 2.0 would represent a significant overhaul of the current framework and signals the evolution of SFDR into a product categorisation-based framework Further detail can be found in section 1.1 of the newsletter. Walkers Asset Management and Investment Funds group have published an advisory analysing the impact of the proposed SFDR 2.0 reforms.
Taxonomy related developments
Measures to simplify the Taxonomy framework continued apace with the Commission Delegated Regulation (EU) 2026/73 ("Taxonomy Omnibus Delegated Act") becoming effective on 28 January 2026, with in-scope undertakings are given the option to delay application of the new measures until the 2026 reporting period.
The Commission is undertaking further work and seeking technical input to complete the review and simplification of taxonomy reporting under the Disclosures Delegated Act.
Further detail can be found in section 2 of the newsletter.
Other ESG related developments
On 14 January 2026, ESMA published a thematic note on clear, fair and not misleading sustainability-related claims focusing on ESG strategies particularly with reference to ESG integration and ESG exclusions.
The note provides practical "do's and don'ts" for market participants to follow to ensure claims in marketing communications regarding ESG strategies are not misleading.
Further detail can be found in section 3.5 of the newsletter.
On 26 February 2026, the Central Bank published its Regulatory and Supervisory Outlook Report ("RSO") outlining the key trends and risks which it has identified as moulding the operating landscape of the financial sector as well as the Central Bank's consequent regulatory and supervisory priorities for the coming year The 3rd edition of the RSO highlights the focus of the Central Bank's efforts on the effectiveness of the governance, risk management practices and culture of firms, and highlights its forward-looking ESG commitments for 2026
Further detail can be found in section 3.1 of the newsletter
1. SDFR-related developments
1.1 SFDR 2.0 proposal
On 20 November 2025, the Commission released the legislative text of a proposed set of amendments to (Regulation (EU) 2019/2088) ("SFDR") and repealing Commission Delegated Regulation ((EU) 2022/1288) ("SFDR Delegated Regulation") ("SFDR 2.0"), alongside a press release, frequently asked questions (outlining the key elements of the proposal) and impact assessment accompanying the proposal and summary of the impact assessment.
The goal of SFDR 2.0 is make SFDR more efficient, simple and proportionate and a key part of this objective is safeguarding the integrity of the EU single market by ensuring requirements which mitigate risks of greenwashing and aid investors in seizing and comparing opportunities in SFDR products, while also boosting the EU's financial sector's competitiveness.
The SFDR 2.0 proposal signals the evolution of SFDR into a product categorisation-based framework and represents a significant overhaul of the current framework underpinned by two central themes:
- Simplification of and reduction in the sustainability related administrative and disclosure requirements for financial market participants ("FMPs") and financial advisers and enhancement of the coherence of it for FMPs operational needs; and
- Improvement of end-investors' ability to understand and compare sustainability-linked financial products and protection against potentially misleading ESG claims.
ESG product categories will be revised, and the below table provides a comparison of the product-level disclosure requirements for the different categories of products under the proposed regime:
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
