On 1 July 2026, the CSSF published a communication drawing market participants' attention to two key developments arising from the ESG Ratings Regulation (Regulation (EU) 2024/3005)
ESG Rating disclosure
First, the Regulation began to apply on 2 July 2026.
Second, Article 49 [LM1] of the Regulation amends Article 13 of the SFDR (Regulation (EU) 2019/2088): financial market participants and financial advisers in scope of the SFDR that issue or disclose an ESG rating (as defined in Article 3(1)) [LM2] in their marketing communications must (a) publish on their website the information required by point 1 of Annex III of the ESG Ratings Regulation and (b) include a link to those website disclosures in the relevant marketing communications.
The CSSF expects full compliance as from 2 July 2026.
Transitional period for full authorisation
The communication also addresses the transitional period from 2 July to 2 November 2026, during which providers already active in the EU on 2 January 2025 must submit a full application for authorisation or recognition to ESMA. Consistent with the ESMA public statement issued on the same date, the CSSF acknowledges that during this period third-party distributors may continue to publish or distribute ESG ratings issued by providers that have notified ESMA of their intention to continue operating in the EU, until ESMA adopts a decision on the relevant authorisation, recognition, or registration.
The CSSF has indicated it will adopt a proportionate supervisory approach, taking into account remaining uncertainties - including that several delegated regulations under the ESG Ratings Regulation (including C(2026)3334) have not yet been published in the Official Journal.
For a detailed breakdown of what this means for you, please refer to our full article on our website.
Share on
