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The SFDR 2.0 legislative process has now reached a stage at which concrete positions from all three EU institutions are, for the first time, visible on the table. The European Commission published its legislative proposal in November 2025 (you can find our analysis here). The Council's Working Party on Financial Services and the Banking Union (CWP) has been deliberating under the Cypriot Presidency. A series of (confidential) non-papers setting out the options and emerging directions across the key areas of the framework have been circulated in the industry, with the last paper setting out the Cypriot Presidency’s proposal for a compromise position on the topics discussed in the CWP. And in the European Parliament, Rapporteur Gerben-Jan Gerbrandy has published his draft report on 28 April 2026. The draft report is due to be tabled before the Economic and Monetary Affairs Committee (ECON) on 3 June 2026, with an ECON vote pencilled in for 15 July (subject to confirmation). Once ECON has cast its vote, the draft report will proceed to a full plenary vote in the European Parliament, anticipated in summer or early autumn 2026. For more details on the SFDR 2.0 timeline see our current overview.
This briefing sets out a structured, topic-by-topic comparison of these four perspectives: the Commission's original proposal, the substantive feedback that the market has provided through the consultation process and position papers (see our earlier article here), the current direction of travel at Council level, and the Rapporteur’s draft position in the European Parliament. It covers nine principal areas of the framework, including the scope of application, the product categorisation architecture, the 70% investment threshold and its treatment of sovereign debt, minimum exclusions, key definitions, the impact add-on, disclosure templates, alignment with MiFID, IDD and PRIIPs, and the implementation timeline.
The picture that emerges is one of broad institutional alignment on the fundamental architecture, but with meaningful divergence on a number of consequential technical points. The Council and the Parliament do not always move in the same direction, and in several areas - including mandatory versus voluntary PAI disclosure, the treatment of safe harbours, and the extension of scope to structured products and packaged investment products – the Rapporteur draft takes a different position from the current Council discussion. These are precisely the questions that will define the substance of the trilogue negotiations expected to commence in September 2026. As always, we will continue to monitor and report on developments as they unfold.
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